Modern Slavery Policy


1. Policy statement

1.1 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 have 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.

1.2 We are 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, and 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.

1.3 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 representatives and business partners.

1.4 To ensure our compliance with this policy and the Modern Slavery Act 2015, we confirm we have a zero-tolerance policy:

  • of the recruitment of child labour;

  • of the employment of young persons under 18 at night or in hazardous conditions;

  • of paying less than the standard working week national legal limit;

  • of excessive working hours;

  • of inhumane or harsh treatment of employees.

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

2. Responsibility for the policy

2.1 Chris Flemming has overall responsibility for ensuring this policy complies with our legal and

2.2 and ethical obligations, and that all those under our control 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.

2.3 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.

2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.

3. Compliance with the policy

3.1 You must ensure that you read, understand and comply with this policy.

3.2 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.

3.3 You must notify a director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

3.4 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.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify the compliance manager as soon as possible.

3.6 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 a director

3.7 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 a director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

3. Victim Support

A victim of modern slavery may have suffered extensive physical and psychological violence and need to feel they are in a place of safety, kindness and professionalism. EPS are committed to supporting confirmed or suspected victim(s) where

We will support anyone who raises a genuine concern and ensure that they receive the appropriate support required.

As a GLAA licence holder, we are committed to sharing any concerns with the appropriate public bodies if we identify any issues surrounding Modern Slavery.

  • there is a confirmed or suspected victim in a case which is ongoing
  • there is a confirmed or suspected victim in a case which has concluded
  • a victim of exploitation / modern slavery at another business has been referred to EPS for employment or accommodation.

Victims should be assigned a Specific Point of Contact who meets with the individual to determine their needs and is an ongoing contact for them in case of any concerns.

It may not be possible to offer such support to victims connected to an ongoing investigation. In such circumstances, consideration will be given to what avenues for support are able to be offered on a case by case basis, bearing in mind the protection of other victims and the integrity of any ongoing case.

5. Communication and awareness of this policy

5.1 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 regular training will be provided as necessar all suppliers, contractors and business partners will be expected to comply with this policy 

6. Breaches of this policy

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

6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

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