Slavery and Human Trafficking Policy

1.1 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. We have 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 business or in any of our supply chains 

1.2 We are also committed to ensuring there is a transparency in our 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 our  other business partners, and as part of our contracting processes, we include  specific prohibitions against the use of forced, compulsory or trafficked  labour, or anyone held in slavery or servitude, whether adults or children and  we expect that our suppliers will hold their own suppliers to the same high  standards. 

1.3 This policy applies to all persons working for us or on behalf in any capacity, including employees at all levels, directors, contractors, external consultants,  third party representatives and business partners. 

1.4 This policy does not form part of any employee’s contract of employment and  we may amend it at any time 

2. RESPONSIBILITY FOR THE POLICY 

2.1 The directors of Hart Ironmongery have overall responsibility for ensuring this  policy complies with our legal and ethical obligations, and that all those under our  control comply with it

3. COMPLIANCE WITH THE POLICY 

3.1 You must ensure that you read, understand and comply with this policy. 

3.2 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. You are required to avoid any activity that might lead to, or suggest, a  breach of this policy. 

3.3 You must notify your manager as soon as possible if you believe or suspect  that a conflict with this policy has occurred or may occur in future. 

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the  earliest possible stage 

3.5 If you are unsure about whether a particular act, the treatment of workers  more generally, or their working conditions within any tier of our supply chains  constitutes any of the various forms of modern slavery, raise it with your manager 

3.6 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 business or in our supply chains. 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 manager immediately.  

4. COMMUNICATION AND AWARENESS OF THIS POLICY 

4.1 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 regular training will be provided as necessary  

4.2 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

5. BREACHES OF THIS POLICY 

5.1 Any employee who breaches this policy will face disciplinary action, which  could result in dismissal for misconduct or gross misconduct 

5.2 We may terminate our relationship with other individuals and organisations  working on our behalf if they breach this policy