Anti-Slavery and
Human Trafficking Policy

POLICY STATEMENT 

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 to exploit them for personal or commercial gain. West Mercia Energy has a zero-tolerance approach to modern slavery and is 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 any of our supply chains. 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 will 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. This policy applies to all persons working for us, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, and interns.  We will undertake appropriate checks of persons working on our behalf in any capacity, including contractors, external consultants, third-party representatives, and business partners to ensure their compliance with the Modern Slavery Act 2015 and supporting policies (where appropriate). This policy does not form part of any employee's contract of employment, and we may amend it at any time. 

RESPONSIBILITY FOR THE POLICY 

•    The Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. 

•    Senior Management has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, auditing internal control systems and procedures to ensure they are effective in countering modern slavery, and ensuring those reporting to them understand and comply with this policy and are given adequate information on it and the issue of modern slavery in supply chains. 

•    Members of staff 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 Director. WME Version 1 – September 2017 

COMPLIANCE WITH THE POLICY 

•    All employees must read, understand, and comply with this policy.

•    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. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

•    Employees must notify their line manager or call the confidential whistle-blowing helpline 01743 252627 as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. 

•    Employees 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.

•    Employees should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains.

•    If an employee is 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 your line manager or through the whistle-blowing helpline. 

•    West Mercia Energy aims 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 any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should report this via the Grievance Procedure. 

COMMUNICATION AND AWARENESS OF THIS POLICY

Communication of this policy, and the risk our business faces from modern slavery in its supply chains, will form part of the induction process for all individuals who work for West Mercia Energy, and regular updates to maintain and raise awareness will be provided as necessary. West Mercia Energy’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter. 

BREACHES OF THIS POLICY 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. West Mercia Energy may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.