Anti-ModerN slavery Policy

Our approach to identifying and assessing modern slavery risk is embedded within our broader risk management approach; for more information see our Code of Conduct and Ethics Policy.

Risks are identified by individuals across all businesses and functions and at many layers of the organisation. Compliance is considered a principal risk at a Group-level; this risk is subject to review.

In Summary

our principles related to modern slavery and human trafficking

Our commitment to human rights, including our position on forced labour, involuntary labour, child labour, and human trafficking, is outlined in our Code of Conduct and Ethics Policy.

We work in partnership with customers and competitors from partnering industries to seek to share and implement best practice ethical business practices.

These principles are cemented through a comprehensive suite of group policies as outlined in our Code of Conduct and Ethics Policy.

Our principles related to human rights include:

  • We are committed to protecting and preserving the rights of our employees, those employed in our supply chain, and those affected by our operations
  • We are committed to acting in a socially responsible manner, complying with applicable laws, and respecting the communities where we operate
  • We believe that all employment should be freely chosen and commit to refrain from any form of forced or involuntary labour
  • We are opposed to the use of any form of child labour or practices that inhibit the development of children
  • We are alert to the risks vulnerable people may face and seek to ensure that this group is free from discrimination and exploitation
  • We will only work with suppliers whose core values and commitment to ethical business conduct matches our own

Our policies related to modern slavery

Our policies cover our commitment to ensure human rights standards are met globally and help make sure our suppliers uphold similar standards.

We seek to take relevant legislation and the views of internal and external stakeholders into account in the development of any group level policy.

Any proposed new group policy or revisions to an existing policy is subject to review and approval by the Chief Governance Officer and General Counsel.

Human rights, including modern slavery and human trafficking, is embedded within a series of policy; we do not have a standalone specific modern slavery policy.

Our Code of Conduct (the Code) underpins all that we do as a company by setting out our principles and how they apply to our business activities.

It applies to all employees, our subsidiaries and controlled joint ventures, wherever they are located. We encourage our non-controlled joint ventures to adopt the principles of our Code and will only work with partners with companies who demonstrate the same commitment to high standards of ethical conduct.

Our Code is available in multiple formats, including hardcopy, online and in a mobile application.

Our Code is supported by our Group Policies manual, which brings together all our Group-wide policies.

Our Human Rights policy sits within this and sets out our commitment to respect the human rights of our employees and those working on our behalf through core labour standards.

The policy draws from broader people-related policies, including our anti-discrimination policy; health, safety and environment (HSE) policy; diversity and inclusion policy; immigration policy; and relocation policy.

Mitigating modern slavery risk in our business operations and activities

The management of human rights risk and impact in our business operations is embedded into existing management systems and processes. Our management teams are responsible for ensuring compliance with local laws and regulations. Our functional teams work with the business leaders to ensure compliance with this policy.

All employees receive regular communications and mandated training on ethical behaviours; we track completion of this training as part of our all employee performance metrics. Where appropriate, we provide additional training on the standards and principles referred to in our Code of Conduct and Ethics Policy.

In particular we support awareness training with groups that have direct oversight into human rights related concerns. We encourage the raising of questions and concerns related to ethical business practices and provide a range of channels for raising questions or concerns, anonymously if desired.

Concerns raised are reviewed by subject matter experts within the Group and by the Safety, Ethics & Sustainability Committee; we also seek external counsel where required. In the event that any future investigation identifies confirmed or potential victims of modern slavery we will work to the best interests and protection of these individuals or groups.