CAW Ventures Ltd (“the Company”, “we”, “us”) understands modern slavery can take many forms including but not limited to human trafficking, forced labour, slavery and servitude (“Modern Slavery”).
The Company recognises the importance of ensuring Modern Slavery finds no place within its organisation, clients, or within its (or its clients) supply chain. We are committed to making our approach to Modern Slavery transparent in line with our obligations under the Modern Slavery Act 2015 (“MSA”) and expect our suppliers to act in a way which matches the standards we hold in relation to this.
This Policy does not form part of any persons’ contract of employment with the Company, and we reserve the right to amend it as and when we see fit.
Modern Slavery Policy
As a company, CAW Ventures Ltd condemns Modern Slavery and refuses to knowingly conduct business with any persons or companies involved in or who condone such practices.
The Company values diversity and prides itself in having high ethical standards on how it conducts its business. We fully support the Government’s objectives behind the MSA and this statement affirms our intention to act ethically in all business we conduct and with our business relations.
We expect everyone who works for us or on our behalf, in any capacity to have a zero-tolerance towards Modern Slavery.
We undertake checks on all our employees, contractors and clients prior to them beginning their engagement with us. This includes checking, where applicable, that the employee has a valid work visa and is of an appropriate age to work.
We are committed to training our employees, contractors, and clients to understand what Modern Slavery involves, and how to identify it in practice. All employees and contractors are expected to report any known or suspected breaches of this policy to their line manager as soon as possible.
As part of this statement we will outline a Modern Slavery & Human Trafficking action plan for the year ahead to help continually improve our ethical employment standards and compliance with the MSA. Performance against this action plan will be reviewed on an annual basis with new actions set the following year in response to emerging risks.
Training and Communication
All new employees and contractors will be briefed on Anti-Bribery & Corruption practises (ABC) and every employee, contractor and board member may be required to annually complete an ABC compliance statement. Commencing from 2019 the ABC briefing will be expanded to incorporate Modern Slavery awareness and all employees will be required to complete an MSA compliance statement.
This Policy Statement will be made available to all staff, contractors, and clients via the internal Policy depository and made accessible to any external stakeholders via the website.
Responsibility for this Policy
The Company’s Directors have approved this Policy Statement and shall take overall responsibility for it.
This Policy Statement shall be reviewed by the Internal Auditor on an annual basis, in co-ordination with the Legal Department and Procurement Department, to ensure it is fully effective in countering Modern Slavery, and also dealing with any queries relating to it.
All Line Managers are responsible for making sure that persons reporting to them fully understand and comply with the Policy. This includes being responsible for ensuring any suggested improvements are incorporated into the Policy if such changes will increase its effectiveness.
CAW Ventures Ltd
1st May, 2019