Anti Slavery, Child Labor, and Anti Trafficking Policy

Policy and Principles

1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and/or compulsory labor, human trafficking, and child labor whether paid or unpaid, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

2. Goodfellow operate a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are also committed 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.

3. Goodfellow complies with the requirements of the Modern Slavery Act 2015 in preventing modern slavery both within Goodfellow and within our supply chains. We aim to ensure transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

4. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting process, we include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, or child labor, and we expect that our suppliers will hold their own suppliers to the same high standards.

5. 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 representative and business partners.

6. All employees are expected to read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for Goodfellow or under Goodfellow association.

7. This policy does not form part of an employee’s contract of employment, and we reserve the right to remove or amend it at any time.


Responsibility for the policy

8. The Board of Directors has overall responsibility for ensuring this policy follows our legal and ethical obligations, and that all those under our control comply with it.

9. The Chief Operating Officer 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.

10. 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.


Communication and Awareness of this Policy

11. Training on this policy, and on the risk our business faces from modern slavery in its supply chains form part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

12. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of Goodfellow’s business relationship with them and reinforced as appropriate thereafter.


Breaches of Policy

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


Compliance with the Modern Slavery Act 2015

14. In tackling modern slavery, we aim to:

a. Protect our reputation and brand.

b. Protect and grow our customer base with higher ethical standards.

c.    Improve clients’ confidence.

d. Act in line with our values.

e. Develop more responsive, stable, and innovative supply chains.

15. We will produce an annual statement at such time that the Goodfellow annual global turnover exceeds the threshold indicated by section 54 of the Modern Slavery Act 2015.

16. When published, the statement will include the following areas:

a. The business structure, its business and supply chains.

b. Its policy to slavery, human trafficking, and child labor.

c.  Its due diligence processes.

d. Any areas of the business or supply chains that may be at risk of slavery, human trafficking or child labor taking place and steps taken to assess and manage any risk.

e. The effectiveness of the policy and actions of the business in ensuring human trafficking, slavery and child labor do not take place in the business or supply chains.

f.    The training available to employees.

17. Each year the Chief Operating Officer will be responsible for reviewing Goodfellow’s annual turnover and publishing the Modern Slavery statement publicly if required.

Prevention of Hidden Labor Exploitation

18. Hidden labor exploitation is exploitation of job applicants or workers by third party individuals or gangs other than the employer or labor provider including rogue individuals working within these businesses but without the knowledge of the management.

19. It includes forced labor, human trafficking, and child labor for labor exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation.

20. It is understood that it is often well hidden by the perpetrators with victims, reluctant to come forward for support.

21. The company shall ensure the following commitments are adhered to:

a. Ensure appropriate individuals in the Company attend “GLAA – What are you doing? (Tackling Hidden Labor Exploitation)” training and have responsibility for developing and operating company procedures relevant to the issue.

b. Accept that job finding fees are a business cost and will not allow these to be paid by the job applicants. The Company will not use any individuals or organisations to source and supply workers without confirming that workers are not being charged a work finding fee.

c.    Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labor exploitation.

d. Ensure that the labor sourcing, recruitment, and worker placement processes are under the control of the HR department.

e. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and Police.

f.    Provide information on tackling “Hidden Labor Exploitation” to the workforce through medium such as workplace posters, induction, and training.

g.    Encourage workers to report cases of hidden third-party labor exploitation, provide the means to do so and investigate and act on reports appropriately.

h. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities to the Chief Operating Officer.

i.    Require labor providers and other organisations in the labor supply chain to adopt policies and procedures consistent with the above.

If any employee is found to be involved with perpetrators of “Hidden Labor Exploitation” following investigation, then disciplinary action will be taken which may lead to dismissal and the Company reserves the right to inform the Police if appropriate.

Prevention of Child Labor

22. Child labour is the exploitation of children through any form of work that deprives them of their childhood, interferes with their ability to attend regular school, or is mentally, physically, socially and morally harmful. Such exploitation is prohibited by legislation worldwide.

23. The company shall ensure the following commitments are adhered to: a. To not employ children under the age of 16 to work in the UK.

b. The company will comply with all applicable child labor laws, including those related to wages, hours worked, overtime and working conditions.

c.  The company is against all forms of exploitation of children. The company does not provide employment to children before they have reached the legal age to have completed their compulsory education, as defined by the relevant authorities.

d. The company requires all labor providers and other organisations in the labor supply chain to have and uphold similar standards and abide by country-governing laws in countries wherein they operate.


Incidents or concerns regarding modern slavery

24. All employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. Any concerns should be raised directly with the Chief Operating Officer.

25. If an employee has concerns about modern slavery and does not feel able to report their concerns to the Chief Operating Officer, they may choose to inform the Modern Slavery Helpline on 0800 0121 700 alternatively they may wish to consult with the Whistleblowing policy.

26. Any concerns raised will be fully investigated and reviewed by a member of the Board of Directors. If the investigation finds any acts of modern slavery, it will be reported to the police and/ or the Modern Slavery Helpline immediately.

27. If modern slavery is identified or suspected abroad, then the response will be tailored to the local circumstances. In some cases, the most appropriate response will be to engage with local NGOs, industry bodies, trade unions or other support organisations to attempt to remedy the situation. In other cases, it will be more appropriate to contact local Government and law enforcement bodies. We will always consider which approach would produce the safest outcome for the potential victims.

28. If any suppliers or associated companies of Goodfellow are found to be acting in a way that may be in breach of modern slavery policies, we will aim to support the business to provide training, communication, or guidance to implement anti-slavery policies.

29. If a supplier is not taking their responsibilities seriously after receiving support Goodfellow may reconsider the commercial relationship and these actions will be included in the annual statement.

30. 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 unfounded. 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.

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