Modern Slavery and Human Trafficking Policy
POLICY STATEMENT
Modern slavery is a crime and a violation of fundamental human rights. It involves the deprivation of an individual’s liberty by another in order to exploit them for personal and/or commercial gain.
At Ross Promotional Products Ltd, we are committed to promoting human rights and conducting business ethically and with integrity at all times. We have a zero-tolerance approach to any form of Modern Slavery: Modern Slavery is against our core values and standards and the presence of Modern Slavery in any part of our business or supply chains will not be tolerated.
Ross Promotional Products Ltd will endeavour to ensure that we comply with all applicable laws, regulations and relevant standards relating to Modern Slavery in all its operations, including the Modern Slavery Act 2015 (the “MSA 2015”). We are committed to ensuring there is transparency in our business and in our approach to tackling Modern Slavery throughout our supply chains, consistent with best practice. More broadly, we will take steps to ensure that they do not benefit directly or indirectly from Modern Slavery or other breaches of human rights in their operations.
Definitions
For the purposes of this Policy:
“Company” means Ross Promotional Products Ltd
“Business Partner” means any customer, contractor, sub-contractor, consultant, agent, supplier of Ross Promotional Products Ltd.
“Employee” means all persons working for us on our behalf in any capacity, including Employees at all levels, directors, officers, agency workers, seconded workers, volunteers and interns.
“Modern Slavery” means slavery, servitude, forced or compulsory labour and human trafficking.
Scope
This Policy applies to all Business Partners of the Company and explains what is expected of you. You must act in accordance with the terms of this Policy and according to the spirit and the values it embodies in whatever you do for the Company.
We are committed to working only with Business Partners whose business ethics and behaviours are consistent with this Policy. In respect of such Business Partners, we will seek to encourage and ensure equivalent compliance.
Our approach to Modern Slavery
We have a zero-tolerance policy for Modern Slavery and Human Trafficking in our organisation or supply chain and we are committed to working with our Employees and Business Partners to address the risk of Modern Slavery in our business or supply chain.
We take a risk based approach and assess whether the circumstances of specific elements of our business warrant the need for additional investigation or protections to prevent Modern Slavery.
Consistent with this risk based approach, we will require Business Partners and Employees to remain vigilant to the possibility of Modern Slavery, and confirm compliance with this Policy.
Responsibility
Whilst ultimate responsibility for the Company’s compliance with its Modern Slavery-related legal and ethical obligations rests with the Directors, 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, on our behalf or under our control. Accordingly, any activity that might lead to, or suggest, a breach of this Policy must be avoided.
All staff must ensure that they read, understand, and comply with this Policy. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
The Directors are responsible for ensuring that everyone in the Company understands and complies with this Policy on a day-to-day basis. Such responsibility includes ensuring the communication of our zero-tolerance approach to Modern Slavery in our business and supply chains to all Business Partners at the outset of any business relationship.
This should be reinforced by requiring Business Partners to confirm their adherence to our policy.
Reporting a Violation
Any known, suspected or potential violation of this Policy must be reported promptly to the Directors.
Employees must bring any known, suspected or potential violations of this Policy to the immediate attention of the Company. You are encouraged to raise concerns about any issue or suspicion of Modern Slavery in any part of the Company’s business or supply chain at the earliest possible stage.
We 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 is or may be taking place in any part of our business or in our supply chain. If you believe that you have suffered detrimental treatment, you should inform the Directors immediately.
Breaches of this Policy
Failure to adhere to this Policy may lead to disciplinary action, up to and including termination of employment or termination of a business relationship.
The Company may terminate their relationship with any individual or organisation working on their behalf who breaches, or who is reasonably suspected of having breached, this Policy, or who, having been given, in appropriate circumstances, an opportunity to remedy any failings and improve to an acceptable standard, has not done so.
Monitoring and Risk Assessment
The suitability and adequacy of this Policy and responses to particular issues will be reviewed periodically. The company’s compliance with this Policy, and, where appropriate, that of Business Partners, will be monitored through a combination of methods, including internal auditing of control systems and procedures to ensure they are effective in countering Modern Slavery and periodic risk assessments. Such risk assessments will be used to identify both specific areas where there may be heightened risk and those Business Partners in our supply chains who could be considered to present higher risk, with a view to understanding the controls they have in place and the operation and adequacy of such controls.
All Employees of the Company will be required to confirm that they have read and understood the requirements of this Policy.
The Directors will be responsible for ensuring the investigation of any reported violations of this Policy.
Last updated March 2024
Any queries concerning this Policy should be addressed to the Directors, Ross Promotional Products Ltd, 60 Elliot Street, Glasgow, G3 8DZ
