ANTI-SLAVERY POLICY STATEMENT 
 

Bluefriars Group Limited including all its subsidiary companies  (‘The Group’) have a zero-tolerance approach to modern slavery, and the Group is 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, our partners or in any of our supply chains. 

 

The Group is 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. 

 

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 expect the same high standards from all of our Appointed Representatives, business partners, customers,  contractors, suppliers and other partners, and as part of our contracting processes, we will 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 all of the above list will hold their own suppliers to the same high standards. 

 

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, Appointed Representatives, third-party representatives and business partners. 

 

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

Responsibility for the policy 

 

The Group has overall responsibility for ensuring this policy complies with our legal, regulatory and ethical obligations, and that all those under our control comply with it. 

 

The Group 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. 

 

 

Compliance with the policy 

The Group will ensure that all staff read, understand and comply with this policy. 

 

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

 

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. 

 

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director or report it in accordance with our Whistleblowing Policy as soon as possible. 

 

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains. 

 

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 line manager or company Director. 

 

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 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. 

​

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 

 

Any employee who breaches this policy may 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. 
 

 

Monitoring and Review

The Group seeks to proactively prevent and mitigate instances of non-compliance with this policy. 

 

Any breaches or concerns, including ethical concerns or potential breaches, should be reported as soon as possible through The Group’s  Whistleblowing channels. 

 

This Policy shall be reviewed at least annually by the Compliance Team. 

 

Staff may request an amendment to this Policy at any time by approaching the Compliance Team in writing, who may or may not authorise the request at their absolute discretion. Any material amendments to this Policy must be approved by the Group’s board.