Slavery & Human Trafficking Policy

1. Introduction

We know that slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global and growing issue, existing in every region in the world and in every type of economy.

Subtech has a zero tolerance approach to Modern Slavery of any kind within our operations and supply chain. Subtech has a responsibility to be alert to the risks of slavery and human trafficking in our business and in our work with third party vendors and suppliers. Thus, employees are expected to report such concerns and management are expected to act upon them.

The purpose of this document is to set out Subtech policy in relation to Slavery and Human Trafficking.

 

2. Scope

The policy applies strictly to all employees, directors, agents, consultants, contractors, suppliers and to any other people or bodies associated with The Subtech Group, within all regions, areas and functions.

 

3. Understanding and Recognising Slavery & Human Trafficking

Human trafficking involves recruitment, harbouring or transporting people into a situation of exploitation through the use of violence, deception or coercion and forced to work against their will.

In other words, trafficking is a process of enslaving people, coercing them into a situation with no way out, and exploiting them.

People can be trafficked for many different forms of exploitation such as forced prostitution, forced labour, forced begging, forced criminality, domestic servitude, forced marriage, and forced organ removal.

 

4. Subtech’s Policy

The Subtech Group will not tolerate slavery and human trafficking in any form.

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. This Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place.

Subtech shall where ever practicable:

  • Undertake human rights assessments, utilising existing best guidance, to identify those areas of our business where there may be higher risk of human rights abuse, including modern slavery, forced labour and human trafficking
  • Avoid causing or contributing to modern slavery and other adverse human rights impacts through our own activities, and address such impacts
  • Seek to prevent or mitigate adverse human rights impacts that are directly related to our operations, services or through our business relationships
  • In the unlikely event, that we have caused or contributed to adverse human rights impacts, Subtech shall provide for or cooperate in their remediation through legitimate processes

 

5. Approach

Our approach to addressing modern slavery is an integrated component of our overall approach to human rights and business conduct.

We have group policies in place to manage the risk of human rights abuses, including modern slavery and human trafficking, within our own operations and in those of our suppliers and business partners.

The above mentioned policies are listed as:

  • Code of Conduct – Employee Practices
  • Sustainability Policy
  • Code of Conduct – Employee Practices

 

5.1. Code of Conduct – Employment Practices

Our Code of Conduct provides a framework of binding principles for all our operations within the Subtech Group. The Code of Conduct also forms the basis of the Subtech Group’s commitment to sustainability. It encompasses the obligation of the Subtech Group employees to take account of economic, environmental, safety, health, quality and social impacts when making business decisions.

 

5.2. Sustainability Policy

The Sustainability Policy statement provides a framework for sustainable and responsible operations, activities, and practices across the Subtech Group. It aims to demonstrate leadership as a professional association in sustainable development and to work towards developing a sustainable company that will instill sustainability values and principles across all of its employees.

 

5.3. Code of Conduct – Supplier Practices

Our Code of Conduct for Suppliers sets out minimum standards and expectations for environmental, social and ethical performance for all our suppliers, including modern slavery and human trafficking aspects.

 

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and with our customers, third party vendors and suppliers, we will include training and this Policy to all relevant individuals and entities. All employees have been informed of Subtech’s expectations regarding slavery and human trafficking via the annual induction process and the James Fisher online training modules.

 

7. Employee Responsibility and How to Raise A Concern

The prevention, detection and reporting of slavery and human trafficking is the responsibility of all employees throughout Subtech. If you become aware or suspect slavery and human trafficking conduct, then you have a duty to report this.

Any such incidents should be reported in accordance Subtech’s whistle blowing policy or to the Group SHEQ Compliance Manager.

 

8. References

James Fisher and Sons Plc – Slavery and Human Trafficking Policy
PRO – HUM – 046 – Whistle Blowing Policy
POL – 011 – Sustainability Policy
PRO – HUM – 017 – Code of Conduct – Employment Practices
PRO – PUR – 002 – Code of Conduct – Supplier Practices
United Kingdom – Modern Slavery Act 2015
South Africa – Prevention and Combating of Trafficking in Persons Act, 2013
International Labour Standards