Modern Slavery & Human Trafficking Policy

Policy statement

emu24 is committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems to ensure modern slavery and human trafficking is not taking place anywhere in our own business or in any of our supply chains.

Modern slavery is a crime and a violation of fundamental human rights. We comply with the Modern Slavery Act 2015 and are committed to transparency in our approach to tackling modern slavery throughout our supply chains and our own business.

Scope

This policy applies to all persons working for emu24 or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

What is modern slavery?

Slavery, servitude & forced or compulsory labour

Slavery is when a person owns or controls another, treating them as property. Servitude involves an obligation to provide services imposed by coercion. Forced or compulsory labour means work exacted from a person under the menace of a penalty and for which they have not voluntarily offered themselves.

Human trafficking

Human trafficking involves arranging or facilitating the travel of another person with a view to that person being exploited. Trafficking can take place within or across national borders.

Our commitments

• We will not use forced, compulsory or trafficked labour, or anyone held in slavery or servitude
• We expect the same standards from all our suppliers, contractors and business partners
• We will implement due diligence procedures for our own business and supply chain
• We will provide training to our staff to help them identify and report signs of modern slavery
• We will support and protect any person who raises a concern about modern slavery in good faith

Due diligence

Before engaging any new supplier or contractor, we conduct appropriate due diligence including reviewing their modern slavery commitments and employment practices. We include compliance with this policy as a condition of business for all suppliers, and reserve the right to audit our supply chain and terminate relationships where breaches are identified.

Training

All employees will be made aware of this policy as part of their induction. Employees in procurement roles will receive targeted training on identifying and preventing modern slavery, updated regularly.

Reporting concerns

Reports should be made to a Director, or via the Company's whistleblowing procedure. All reports will be treated confidentially and investigated promptly. No individual will be penalised for raising a concern in good faith.

Governance & review

The Managing Director has overall responsibility for this policy. This policy will be reviewed annually. A Modern Slavery Transparency Statement will be published on the emu24 website each financial year.