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Modern Slavery Policy

Introduction

This policy pertains to Neville Trust Limited (hereinafter referred to as the Company).

Policy

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.  The Company understands that this requires an ongoing review of both its internal practices in relation to its workforce and its supply chains.  The Company does not enter into business with any other organisation (in the United Kingdom or overseas) which knowingly supports or is found to involve itself in modern slavery.  No labour provided to the Company in the provision of its services is obtained by means of slavery or human trafficking.  The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Definitions

Modern slavery is the severe exploitation of other people for personal or commercial gain.  The Company considers that modern slavery encompasses the following:

  • human trafficking

  • forced labour

  • debt bondage/bonded labour

  • slavery of children

  • sexual exploitation

  • criminal exploitation

  • cultural exploitation

  • organ harvesting trafficking

Control Measures

In general, the Company considers its exposure to modern slavery to be relatively limited.  The Company carries out due diligence processes in relation to ensuring modern slavery does not take place in its organisation or supply chains.  The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

Responsibilities

The Company Directors have ultimate responsibility in ensuring that the Company maintains a zero-tolerance stance towards modern slavery.  However, managers must also ensure that their practices and interactions with third parties are in accordance with this policy.  It is also the responsibility of every employee to ensure they escalate any information, or suspicions which lead them to believe that modern slavery practices are occurring.  Employees should immediately advise their Line Manager, the Company Secretary or the HR Department of any concerns or suspicions.

Further, if you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions might be an act of modern slavery, you should immediately raise your concerns with your Line Manager or the HR Department. 

The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting modern slavery concerns under the Whistleblowing Policy.

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