Anti-Slavery Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,
such as slavery, servitude, forced and 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.
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Shortwork Limited has a zero-tolerance approach to modern slavery, and 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 business or in any of our supply chains.
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We are also 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.
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We expect the same high standards from all of our contractors, suppliers and other business
partners, and we expect that our suppliers will hold their own suppliers to the same high standards.
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This policy applies to all persons working for us or on our behalf in any capacity, including
our director and the external consultants that we collaborate with.
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Responsibility for the policy
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The Company has overall responsibility for ensuring this policy complies with our legal and
ethical obligations, and that all those under our control comply with it.
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The Company has primary and day-to-day responsibility for implementing this policy, monitoring
its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and
comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
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Compliance with the policy
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The prevention, detection and reporting of modern slavery in any part of our business or supply
chains is the responsibility of all those working for us or under our control.
The company directors and consultants are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Any potential breaches must be reported to the Company Director at the earliest possible stage.
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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.
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Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable
treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your line manager
immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.
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Communication & awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply
chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers,
contractors and business partners at the outset of our business relationship with them and
reinforced as appropriate thereafter.
Breaches of this policy
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Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct. We may terminate our relationship with other
individuals and organisations working on our behalf if they breach this policy.
Printed and Signed Off By: Rowena Hay, January 2023