MODERN SLAVERY (ANTI_SLAVERY & HUMAN TRAFFICKING) POLICY
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.
Slavery and Human Trafficking remains a hidden blight on our global society. We all have a
responsibility to be alert to the risks, however small, in our business and in the wider supply
2. POLICY PURPOSE
Previsico Ltd (the Company) has 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 own business or in any of our supply chains.
The Company 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. We expect the same high
standards from all of our contractors, suppliers and other business partners. 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.
This policy applies to all persons working for the Company 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. This policy does not form part of any employee’s contract of employment
and the Company may amend it at any time.
4. RELATED POLICIES AND PROCEDURES
This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the following
workplace policies and procedures which can be found in the Company Policies. You are
encouraged to familiarise yourself with the policy detailed below.
• Previsico Whistleblowing policy
5. RESPONSIBILITY FOR POLICY
The Company Board have overall responsibility for ensuring this policy with senior
management; and managers have day to day responsibility to ensure compliance with our
legal and ethical obligation 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.
6. COMPLIANCE WITH THIS POLICY
You must ensure that you 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
manager 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 manager or you may report it in accordance with our Whistleblowing Policy as soon
as possible. 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. 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.
The Company is 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 management immediately. If the matter is not remedied, and you are an
employee, you should raise it formally using the Grievance Procedure which can be found in
the Company Policies or from the HR department.
7. COMMUNICATION AND AWARENESS OF THIS POLICY
Training on this policy, and on the risk our business faces from modern slavery in its supply
chains, will be provided as necessary. 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. All employees
receive an induction into the business where our policies, procedures and expectations are
8. BREACHES OF THIS POLICY
Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct. The Company may terminate our relations