This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners, and suppliers
Caulfield Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect our suppliers to hold their own suppliers to the same high standards.
Modern Slavery and Human Trafficking Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. They must be informed of this policy and must confirm their compliance with it. If we find that other individuals or organisations working on our behalf have breached this policy, we will take appropriate action.
The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Board reviews this policy annually.
Communication: This policy is available on our company website and is maintained on our MSTeams “Wall” which is readily available to all employees and suppliers. This policy is also communicated to all our employees upon commencing their employment. This policy is included in our sub-contract procurement documentation and is referenced on all Purchase Orders.
Continuous Improvement: In the last financial year, we have been implementing a rigorous supplier approval process. This requires all suppliers to self-certify their commitment to anti-slavery, and it includes verification checks on our part. We are currently developing a training course on anti-slavery and human trafficking for our staff.
D Milne (Director) Date: 01.02.2022