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Modern slavery statement

SLC Rail and SLC Property maintains relationships with many different organisations in its supply chain as well as directly employing individuals. Following on from the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and the risk management processes to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of the business or in its supply chains.

We expect all or who have, or seek to have, a business relationship with SLC Rail and SLC Property, to familiarise themselves with our antislavery policy and to act at all times in a way which is consistent with its values. Zero tolerance is at the core of our policy.

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the ‘Act’). Modern slavery can occur in various forms, including servitude, forced or 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. This document sets out the policy of SLC Rail and SLC Property with the aim of the prevention of opportunities for modern slavery to occur within its business or supply chain. This policy’s use of the term ‘modern slavery’ has the meaning given in the Act.

Ultimate responsibility for the prevention and the prevention of modern slavery rests with the Company’s leadership. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation complies with its legal and ethical obligations.

Managers and Team Leaders at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

The company has a zero-tolerance approach to modern slavery. It is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our Company or those of its suppliers.

Steps for the prevention of modern slavery

The Company is committed to ensuring there is transparency in its own business and in our approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all of its contractors, suppliers and other business partners, and the
Company is evolving and updating our contracting processes to include specific prohibitions against the used force, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. The Company expects its suppliers to hold their own suppliers to the same high standards.

All employees have an obligation to familiarise themselves with the Company’s procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented. Adherence to this policy forms part of all employees’ obligations under their contract of employment.

Whilst recognising the Company’s statutory obligation to set out the steps it should take to ensure that modern slavery and human trafficking is not taking place in its supply chains, the Company acknowledges that it does not control the conduct of individuals and organisations in its supply chains.

To underpin its compliance with practical steps, the Company intends to implement the following measures:

  • Conduct risk assessments to determine which parts of the business and which of the Company’s suppliers are most at risk of modern slavery so that efforts can be focused on those areas;
  • Engage with the Company’s suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses;
  • Where appropriate, as informed by the Company’s risk assessment, seek to introduce further supplier pre- screening (for example as part of our tender process) and self-reporting for our suppliers on safeguarding controls;
  • Introduce contractual provisions for the Company’s suppliers to confirm their adherence to this policy and accept the Company’s right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.

The Company’s Whistleblowing Policy is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or its suppliers may be reported by employees in this manner.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
We will terminate our relationship with other individuals and organisations working on our behalf if they materially breach this policy

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed on a regular basis (at least annually) and may be amended from time to time.