1. Policy statement

1.1 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 in order to exploit them for personal or commercial gain. Spectra Group (UK) Ltd (“Spectra”) has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any of its supply chains.

1.2 Spectra is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. Spectra expects the same high standards from all of its contractors, suppliers and other business partners, and as part of your contracting processes, Spectra requires the inclusion of prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

1.3 This policy applies to all persons working for Spectra or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, suppliers, external consultants, third-party representatives and business partners.

1.4 Spectra may amend this policy at any time.


2. Responsibility for the policy

2.1 Simon Davies (Director/Chief Executive Officer) has overall responsibility for ensuring this policy complies with Spectra’s legal and ethical obligations.

2.2 The Head of Legal & Business Affairs has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures within Spectra to ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

2.4 You 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 [email protected].


3. Compliance with the policy

3.1 You must ensure that you, and you procure that those under your control, read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of your business or supply chains is the responsibility of all those working for you or under your control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify Spectra as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of Spectra’s business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must report it to your Spectra point of contact as soon as possible.

3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of Spectra’s supply chains constitutes any of the various forms of modern slavery, raise it with your Spectra point of contact.

3.7 Spectra aims to encourage openness and the support of anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Spectra expects you to be 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 Spectra’s own business or in any of its supply chains.


4. Communication and awareness of this policy

4.1 Your approach to addressing the issue of modern slavery in your business and supply chains must be communicated to all your suppliers, contractors and business partners at the outset of your business relationship with them and reinforced as appropriate thereafter.


5. Breaches of this policy

5.1 Spectra may terminate its relationship with individuals and organisations working on its behalf if they breach this policy.