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1. Policy Statement
1.1 Ebla-UK Ltd (“the Company”) acknowledges the abhorrent nature of modern slavery, which includes human trafficking, bonded labour, child labour, and forced labour. These practices are characterised by the deprivation of an individual’s liberty for the purpose of exploitation, whether for personal or commercial gain.
1.2 The Company has a zero-tolerance stance on modern slavery in all its forms. We are committed to conducting all our business dealings with the highest ethical standards and integrity. Furthermore, we are dedicated to implementing and enforcing robust systems and controls to ensure that modern slavery is not present within any part of our own business operations.
1.3 We expect all our contractors, suppliers, and other business partners to meet these same high standards. As a core part of our contractual processes in the coming year, we will include specific prohibitions against the use of forced, compulsory, or trafficked labour, or any individuals held in slavery or servitude, regardless of whether they are adults or children. We also expect that our suppliers will, in turn, hold their own suppliers to these same exacting standards.
1.4 This policy applies to all persons working for the Company or on our behalf in any capacity. This includes, but is not limited to, all employees, directors, officers, agency workers, secondees, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
2. Responsibility for the Policy
2.1 The Board of Directors of Ebla-UK Ltd has ultimate responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations, and that all persons under our control adhere to it.
2.2 The Director of Ebla-UK Ltd has primary and day-to-day responsibility for the implementation of this policy, for monitoring its application and effectiveness, for addressing any enquiries, and for auditing our internal control systems and procedures to ensure they are effective in preventing modern slavery.
3. Compliance with the Policy
3.1 The prevention, detection, and reporting of modern slavery within any part of the Company’s business or supply chains is a collective responsibility shared by everyone working for us or under our control.
3.2 All individuals to whom this policy applies must refrain from any activity that might lead to, or suggest, a contravention of this policy.
3.3 If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, you are obligated to notify your line manager or a Company Director at the earliest opportunity.
3.4 We strongly encourage the raising of concerns regarding any issue or suspicion of modern slavery within any part of our business or the supply chains of any supplier, at any level. If you believe or suspect that a breach of this policy has occurred or may occur, you must notify your line manager or a Company Director, or alternatively, report it in accordance with the procedures outlined in our Employee Handbook, as quickly as possible.
3.5 Where appropriate and with the welfare and safety of local workers as a top priority, the Company will offer support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices within their own businesses and supply chains.
3.6 The Company is committed to fostering an environment of openness and will support any individual who raises genuine concerns in good faith in line with this policy, even if such concerns are ultimately found to be mistaken. We are dedicated to ensuring that no individual suffers any detrimental treatment as a result of reporting, in good faith, their suspicion that modern slavery is or may be occurring within any part of our business or supply chains. This detrimental treatment includes, but is not limited to, dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.
3.7 If you believe that you have been subjected to any such detrimental treatment, you should inform your line manager immediately. If the matter is not resolved, and you are an employee, you should formally raise the matter using our Grievance Procedure, the details of which can be found in the current Employee Handbook.
4. Communication and Awareness
4.1 Training on this policy, and on the risks our business faces from modern slavery within its supply chains, will form part of the induction process for all individuals who work for the Company. Updates will be distributed using established methods of communication between the business and its personnel.
4.2 The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the beginning of our business relationship with them and reinforced as appropriate thereafter.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Ebla-UK Ltd