Equteq Ltd is dedicated to limiting the risk of modern slavery occurring within its own business, invading its service partners or through any other business relationships.
This policy applies to all persons working for or on behalf of the Company, in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative.
Equteq expects all who have, or seek to have, a business relationship with the Company to familiarise themselves with this policy and to act in a way that is consistent with the values expressed in our policies.
The Company will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance to this policy.
This policy will be used to underpin and inform any statement on slavery and human trafficking that the Company is required to produce further to the transparency in requirements of the Modern Slavery Act 2015 (MSA).
What do we mean by Modern Slavery?
Modern slavery can take many forms; it is a complex problem. The Modern Slavery Act (MSA) 2015 covers four key criminal activities:
- Slavery: where ownership is exercised over an individual
- Servitude: involves the obligation to provide service imposed by coercion
- Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty
- Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them
All forms of modern slavery have in common, the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Addressing modern slavery requires colleagues to play a part and remain vigilant to the risk in all aspect of the Equteq business and business relationships.
How Anti-Slavery Policy is put into Practice
- The Company will conduct risk assessments to determine which parts of the business and which service providers are most at risk from modern slavery so efforts can be focused on the areas that are most ‘at risk’
- Where appropriate, as informed by the risk assessment, the Company will engage directly with new service providers in respect of the Anti-Slavery Policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses.
- Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
- We also reserve the right to terminate any contractual arrangement if there is breach of this policy.
Responsibility for this Policy
The Leadership team has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
The Managing Directors will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
Communication & Employee Awareness Training
Line Managers will ensure that relevant colleagues receive adequate training on this policy and any supporting processes applicable to their role.
Breaches of this Policy
The breach of this policy by an employee, director or officer of the Company may lead to disciplinary action being taken in accordance with the Company’s Disciplinary Procedure. Serious breaches may be regarded as gross misconduct and can lead to immediate dismissal.
All colleagues will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.
Standing status of this Policy
This Anti-Slavery Policy will be reviewed by the Managing Directors on a regular basis.
This notice reflects the Company’s current practice. Equteq will update this notice from time to time to reflect legal and operational requirements or improvements.