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Modern Slavery Policy

Modern Slavery (Anti-Slavery & Human Trafficking) Policy

Version: V2
Document Owner: JH
Date: 05/06/2025

1. Introduction

Modern slavery is a serious crime and a gross violation of fundamental human rights. It can take many forms, including:

  • Slavery
  • Servitude
  • Forced and compulsory labour
  • Human trafficking

At its core, modern slavery involves the deprivation of liberty to exploit individuals for personal or commercial gain.

H&H Group has a zero-tolerance approach to modern slavery. We are committed to conducting all our business dealings ethically, transparently and with integrity.

We strive to ensure modern slavery and human trafficking are not taking place in any part of our operations or supply chains.

This policy outlines our responsibilities and expectations and supports our obligations under the Modern Slavery Act 2015 (Section 54: Transparency in Supply Chains). It is designed to inform all relevant stakeholders and will underpin any slavery and human trafficking statements we are required to make.

2. Scope and Applicability

This policy applies to all individuals working for or on behalf of H&H Group in any capacity, including:

  • Employees at all levels
  • Directors and officers
  • Agency and seconded workers
  • Contractors and consultants
  • Volunteers and interns
  • Third-party representatives and business partners
  • Suppliers and service providers

While this policy is not contractual, compliance is expected as part of ethical business conduct. We expect all those connected with the Group to uphold these standards and values in full.

3. Supporting Policies and Procedures

This policy should be read alongside other relevant internal policies, including:

  • Whistleblowing Policy
  • Grievance Procedure
  • Conduct at Work
  • Disciplinary Procedure

These documents reinforce our commitment to ethical practice and offer mechanisms for employees and third parties to report concerns.

4. Roles and Responsibilities

Chief Executive and Senior Management

  • Have ultimate responsibility for ensuring this policy is implemented and adhered to.
  • Provide leadership and ensure strategic oversight.

Managers

  • Ensure day-to-day compliance.
  • Monitor supplier and contractor relationships for risk indicators.
  • Provide training and support to staff on policy implementation.

All Employees and Representatives

  • Must understand, comply with and promote this policy.
  • Are responsible for identifying and reporting risks or breaches.

5. Identifying and Addressing Risks

Modern slavery can occur in various industries and regions.

High-risk indicators include:

  • Poor working conditions and health and safety.
  • Workers with no access to identity documents or personal bank accounts.
  • Excessive working hours or withheld wages.
  • Migrant or seasonal labour with a lack of transparency around employment terms.

Where we identify a potential risk:

  • We will investigate and assess the issue thoroughly.
  • We will work with the relevant party to resolve it ethically.
  • We reserve the right to suspend or terminate relationships if non-compliance continues.

6. Reporting and Raising Concerns

You must act if you suspect any form of modern slavery is taking place.

Raise concerns through any of the following channels:

  • Your line manager
  • Group HR Manager
  • Through our Whistleblowing Policy (for anonymous reporting)

Examples of reportable concerns:

  • A supplier’s workforce appears to be under coercion.
  • Someone reports working excessive hours under threat.
  • Suspicion that wages are being withheld unlawfully.

If you are unsure whether something constitutes modern slavery, report it anyway — we would rather act on a false alarm than ignore a potential issue.

7. Protection for Whistleblowers

H&H Group is committed to protecting anyone who raises concerns in good faith.

You will not be penalised or subjected to:

  • Dismissal
  • Disciplinary action
  • Victimisation
  • Any form of detrimental treatment

If you feel you have experienced retaliation, report it to your manager or raise a grievance in accordance with the company’s Grievance Procedure and Whistleblowing Policy.

8. Training and Awareness

To support this policy:

  • New employees will be introduced to modern slavery risks as part of induction.
  • Additional training will be provided to staff in procurement, HR and senior roles.
  • We will ensure contractors, suppliers and partners are made aware of our zero-tolerance stance and ethical expectations from the outset and throughout the business relationship.

9. Breaches of This Policy

Any employee found to have breached this policy will face disciplinary action, up to and including dismissal for gross misconduct.

We may terminate relationships with any external parties or suppliers who are found to be non-compliant with this policy or who fail to take adequate steps to prevent modern slavery in their own operations or supply chains.

10. Commitment to Transparency

We are committed to meeting our obligations under the Modern Slavery Act 2015, and we will:

  • Publish an annual modern slavery and human trafficking statement.
  • Outline actions taken to assess and address risks.
  • Monitor and improve our due diligence and supplier checks.
  • Ensure policy review and board-level endorsement annually.