1. POLICY STATEMENT
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
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.
1.2 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. We expect the same high standards from all of our contractors, suppliers and
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 our behalf in any capacity, including employees at all
levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, 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 Senior Management Team has overall responsibility for ensuring this policy complies with our legal and
ethical obligations, and that all those under our control comply with it.
2.2 The CEO 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.
2.3 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.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments,
suggestions and queries are encouraged and should be addressed to the CEO.
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 or the CEO as soon as possible if you believe or suspect that a conflict with
this policy has occurred, or may occur in the 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.
Page 2 of 2
ZYBRE Limited Modern Slavery Statement July 2021
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line
manager or the CEO, OR report it in accordance with our Whistleblowing Policy, as soon as possible.
3.6 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 or the CEO.
3.7 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. If you believe that you have suffered any such treatment, you should inform the Head of
People immediately. If the matter is not remedied, and you are an employee, you should raise it formally
using our Grievance Procedure.
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 commitment to addressing the issue of modern slavery in our business and supply chains 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.