MODERN SLAVERY & HUMAN TRAFFICKING POLICY
In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains.
Moussaieff Jewellers Ltd has therefore formulated this policy on the prevention of modern slavery and human trafficking, which governs all our business dealings and the conduct of all persons or organisations with whom we transact. We expect all individuals and organisations who have, or seek to have, a business relationship with us, to familiarise themselves with our anti-slavery policy and to act at all times in a way which is consistent with that policy.
1. PURPOSE OF THIS POLICY
1.1 Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of Moussaieff Jewellers Ltd (the “Company”) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.
1.2 As a Company, we have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.
2. STEPS FOR THE PREVENTION OF MODERN SLAVERY
2.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our suppliers and other business partners, and we are evolving and updating our processes to include prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
2.2 All team members have an obligation to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented.
2.3 Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, the directors have implemented the following measures:
(i) conduct risk assessments to keep under review any areas of our business or our suppliers most at risk of modern slavery, so that efforts can be focused on those areas
(ii) engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
3. RESPONSIBILITY FOR THE POLICY
3.1 Ultimate responsibility for the prevention of modern slavery rests with the directors of the Company who have overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.
3.2 Team members at all levels are responsible for ensuring they comply with this policy and are given adequate training on it and the issue of modern slavery.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.
Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.
Following its adoption, this Modern Slavery and Human Trafficking Policy will be kept under review by the Company’s Directors on a regular basis (at least annually) and may be amended from time to time. This Policy will form the basis upon which we will be issuing our regular annual Modern Slavery and Human Trafficking Statement which will be published following the publication of our Year-end Financial results annually.
Moussaieff Jewellers Limited