1. Policy statement
Modern slavery encompasses slavery, servitude, forced or compulsory labour and human trafficking. Cybercontrols has a zero-tolerance approach to modern slavery in any form. 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 our supply chain.
This policy sits alongside our published Modern Slavery Statement.
2. Scope
This policy applies to all persons working for us or on our behalf in any capacity, including the Director, consultants and contractors representing the Cybercontrols brand, agency workers, volunteers and business partners. It also sets out the standard we expect of our suppliers at every tier.
3. Responsibilities
- The Director has overall responsibility for this policy, for ensuring it complies with our legal and ethical obligations, and for its annual review.
- Consultants and contractors are responsible for reading, understanding and complying with this policy, and for the prevention, detection and reporting of modern slavery in any part of our business or supply chain that they touch.
- Suppliers are expected to maintain equivalent standards within their own operations and supply chains, and to notify us immediately of any concern.
4. Compliance
No one working for or with Cybercontrols may engage in, facilitate, or fail to report modern slavery. In particular, you must not employ or engage anyone who is under age, working involuntarily, or whose identity documents or wages are controlled by another person, and you must not enter into business with any organisation, in the UK or abroad, which you know or reasonably suspect to be involved in modern slavery.
5. Indicators to watch for
Signs that a person may be a victim of modern slavery include: appearing to be under the control of another; unwillingness or inability to speak freely; wages paid to a third party; lack of identity documents; poor physical condition or fearful demeanour; and living at overcrowded or unsuitable addresses shared with many others. A single indicator is not proof, but any indicator warrants a report.
6. Raising concerns
Report it, even if you are not certain. Concerns may be raised directly with the Director, or confidentially and anonymously through SpeakOutSafe, the independent whistleblowing platform we operate. We would far rather investigate an honest concern that proves unfounded than miss a genuine one.
Anyone who raises a concern in good faith will be protected. We will not tolerate retaliation, detrimental treatment or dismissal connected to a good-faith report, whether or not the concern is upheld. Where a concern involves a potential crime, we will refer the matter to the appropriate authorities.
7. Breach of this policy
A breach of this policy by anyone working for us will be treated as a serious disciplinary matter and may result in termination of engagement. For suppliers and business partners, a breach may result in the immediate termination of the relationship.
8. Communication and review
This policy is communicated to everyone working for or on behalf of Cybercontrols at the start of their engagement, and is reviewed annually by the Director or sooner where legislation, guidance or our own circumstances change.