This statement is made pursuant to Section 54, Part 6 of the U.K. Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking are not taking place in its business.
The Company recognizes its social responsibility in the communities in which it operates. As part of the Company’s Compliance & Ethics program, the Company and its employees receive training on and must adhere to a Code of Conduct. The Code of Conduct, and the various written policies that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which the Company operates.
The Company opposes and prohibits the use of human trafficking, child labor, slavery and slave labor, and it expects the same from its business partners and suppliers. As a global business, the Company is committed to compliance with all applicable labor laws, including the U.K.’s Modern Slavery Act.
A core tenet of the Company’s Code of Conduct is that the Company “will not tolerate behavior that endangers” its business partners, and the Company’s Combatting Trafficking in Persons policy requires employees and business partners alike to abide by applicable labor laws. The Company also conducts varying levels of due diligence on its business partners, depending on the potential risk presented by that relationship.
The Company requires its business partners to comply with relevant labor laws and, where applicable, to the relevant provisions of the U.K. Modern Slavery Act.
The Company’s Compliance & Ethics program provides relevant training and a number of venues through which its employees, contractors and business partners can report concerns regarding potential misconduct without fear of retaliation. The U.K. Modern Slavery Act is intended to address supply-chain issues and, although the Company does not generally rely on supply chains for the services it provides, the Company will work to ensure that it does not engage with partners that violate the spirit of such law.
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