Modern Slavery Policy

POLICY STATEMENT

At Connect It All we understand the importance of compliance with the Modern Slavery Act 2015 and endeavour to ensure that requirements of this Act are implemented throughout our business and our supply chain.

We have adopted a proactive approach to mitigating modern slavery and all forms of corruption and bribery, directly and indirectly, associated with these criminal acts.

DEFINITIONS

This policy includes the following definitions:

• Modern Slavery – the term used within the UK to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking and any associated criminal offences.
• Human Trafficking – where a person arranges or facilitates the travel of another person with a view to that person being exploited.

AIMS AND OBJECTIVES

This policy provides a framework to ensure:

• All Connect It All employees understand and are aware of their responsibilities in relation to modern slavery.
• The development of a strategic approach to identifying and tackling any modern slavery within Connect It All and the supply chains.
• The implementation of robust, transparent and proportionate assurance processes.
• The reporting of any, and all, instances or concerns of modern slavery.

SCOPE OF POLICY

This policy applies to all individuals working for or on behalf of Connect It All in any capacity.

Due to the pervasive nature of modern slavery, the scope of this policy extends to our supply chains and all components within.

CONNECT IT ALL ROLES AND RESPONSIBILITIES

• The promotion of ethical business practices and policies that protect all workers from being abused or exploited.
• The prevention, detection and reporting of modern slavery.
• Ensuring that this policy complies with legal and ethical obligations.
• Ensuring that all employees understand and comply with this policy.
• To pay all employees in line with or above National Living Wage and Minimum Wage rates.

EMPLOYEE ROLES AND RESPONSIBILITIES

• To understand their responsibilities in relation to this policy.
• To report any concerns about or instances of modern slavery.
• To complete any training relevant to this policy if requested to do so.

3rd PARTY / SUPPLY CHAIN RESPONSIBILITIES

Connect It All requires all organisations with which it engages to ensure that their goods, services, materials and labour-related supply chains:

• Fully comply with the Modern Slavery Act 2015.
• Are clear, accountable and auditable.
• Are free from ethical ambiguities.
• Suppliers, contractors and other associated 3rd parties are expected to operate to the highest level of ethical standards.
• All components of the Connect It All supply chain should be able to demonstrate how they seek to tackle modern slavery and provide evidence of their own modern slavery policies.

TRAINING, MANAGING AND MONITORING COMPLIANCE

This policy will be reviewed and updated annually to ensure its continued compliance with the Modern Slavery Act 2015.

Appropriate training and guidance will be provided to all employees.

Employees will be notified of any changes to this policy.

All employees will have access to this policy via Sharepoint.

NON-COMPLIANCE, REPORTING AND VICTIM SUPPORT

If any Connect It All employee is discovered to have breached this policy, appropriate action, including but not limited to, disciplinary action will be taken.

We aim to follow a collaborative approach with our supply chain. If any Connect It All 3rd party or supplier is found to have breached this policy, appropriate action will be taken. Where appropriate, and as a last course of action, contracts may be terminated.

Any employee who has reasonable suspicion of or evidence of modern slavery or non-compliance with the Modern Slavery Act 2015 must make a report either to management or to the UK Modern Slavery Helpline on 0800 012 1700.

Connect It All will take a victim-centred approach to modern slavery in order to protect victims from further harm or vulnerability.

EQUALITY IMPACT ASSESSMENT (EIA)

All our policies must comply with relevant legislation. This includes but is not limited to:

• Modern Slavery Act 2015

All employees, colleagues and members of the public should be treated fairly and with respect regardless of any protected characteristics.

POLICY CHANGES

To comply with regulations and legislation in place at the time, changes may periodically be made to this policy and any related policy or procedure.