Anti-Slavery And Modern Slavery Policy

Key Policy Summary

1. Policy Statement

1. Modern slavery is a crime and a serious violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the exploitation of a person for personal or commercial gain.
2. MCR EXEC takes a zero-tolerance approach to modern slavery. We are committed to acting ethically, with integrity, and to implementing appropriate systems and controls designed to reduce the risk of modern slavery within our own business and supply chains.
3. We are committed to transparency in our operations and in the way we address modern slavery risks, consistent with our legal and ethical obligations.
4. We expect equivalent standards from all contractors, suppliers and business partners. We seek to prohibit the use of forced, compulsory or trafficked labour, and any person held in slavery or servitude, whether adult or child, within our commercial relationships and supply chain.

2. Scope And Application

1. This policy applies to all individuals working for or on behalf of MCR EXEC in any capacity, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, consultants, third-party representatives and business partners.
2. This policy is not intended to form part of any employee’s contract of employment, and MCR EXEC reserves the right to amend it from time to time.

3. Policy Responsibilities

1. MCR EXEC is ultimately responsible for ensuring that this policy reflects our legal and ethical commitments and that those acting for or on behalf of the business understand the standards required.
2. MCR EXEC is responsible for the day-to-day implementation of this policy, monitoring its effectiveness, reviewing internal control systems and responding to queries relating to its application.
3. Management at all levels is responsible for promoting awareness of this policy, ensuring appropriate compliance by those reporting to them, and supporting ongoing understanding of modern slavery risks where relevant.
4. Feedback and suggestions for improvement of this policy are welcomed and should be directed to the contact details set out below.

4. Policy Compliance

1. Everyone working for MCR EXEC or under its authority is expected to read, understand and comply with this policy.
2. The prevention, identification and reporting of modern slavery in any part of our business or supply chains is a shared responsibility.
3. No person acting for or on behalf of MCR EXEC should engage in any conduct that could result in, contribute to, or suggest a breach of this policy.
4. Where appropriate, and with the welfare and safety of affected workers as a priority, MCR EXEC may support suppliers in addressing coercive, abusive or exploitative labour practices identified within their operations or supply chains.

5. Reporting Concerns

1. Any person who believes that a conflict with this policy has occurred, is occurring, or may occur should raise the matter as soon as possible with their line manager or a company director.
2. Concerns should be raised promptly in relation to any suspected modern slavery issue in any part of MCR EXEC’s business or any tier of its supply chain.
3. If you are uncertain whether a particular act, working practice or employment condition may amount to modern slavery, you should still raise the matter so that it can be considered appropriately.
4. MCR EXEC seeks to encourage transparency and will support those who raise genuine concerns in good faith, even where those concerns are not ultimately substantiated.
5. MCR EXEC is committed to ensuring that no one suffers detrimental treatment for raising a genuine concern in good faith about modern slavery risks or suspected breaches of this policy.

6. Communication And Awareness

1. Awareness of this policy and the risk of modern slavery in supply chains should form part of the induction process for new employees where relevant to their role.
2. Refresher information or policy updates may be communicated through normal company communication channels as appropriate.
3. MCR EXEC’s zero-tolerance approach to modern slavery should be communicated to suppliers, contractors and business partners at the outset of commercial relationships and reinforced where necessary.

7. Policy Breaches

1. Any employee who breaches this policy may be subject to disciplinary action, which may include dismissal where justified by the seriousness of the conduct.
2. MCR EXEC reserves the right to suspend, review or terminate relationships with other individuals, suppliers, contractors, representatives or organisations acting on its behalf where this policy is breached or where serious concerns arise.

8. Contact Details

1. Any comments, suggestions or queries relating to this policy should be addressed to MCR EXEC using the details below.