Modern Slavery Policy for AS Controls
1. Introduction
AS Controls is committed to conducting its business ethically and with integrity. We acknowledge the severe nature of modern slavery and human trafficking, which constitute grave violations of human rights. This policy outlines our commitment to preventing modern slavery and human trafficking in our operations and supply chains.
2. Scope
This policy applies to all individuals employed by AS Controls, including directors, officers, employees, agency workers, contractors, volunteers, interns, agents, or any other person or persons associated with our organisation. It also applies to our suppliers, contractors and any other entities within our supply chains.
3. Definition of Modern Slavery
Modern slavery is a term used to encompass slavery, servitude, forced or compulsory labour, and human trafficking. Victims are exploited for various purposes, including forced labour, domestic servitude and sexual exploitation.
4. Our Commitment
AS Controls has a zero-tolerance approach to modern slavery. We are committed to:
- Implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains
- Being vigilant for any potential risks of modern slavery and human trafficking
- Protecting whistleblowers and ensuring the confidentiality of those reporting concerns
- Ensuring transparency in our approach to tackling modern slavery and human trafficking
5. Responsibilities
- Senior Management: Sets the tone for our organisation’s commitment to eradicating modern slavery, approves this policyand ensures adequate resources are available for its implementation
- Employees: Are responsible for being aware of the signs of modern slavery and reporting any concerns through the appropriate channels
- Managers: Are responsible for ensuring their teams understand and comply with this policy. They are also responsible for taking appropriate action if concerns are raised
- Procurement/Supply Chain: Is responsible for conducting due diligence on suppliers and ensuring they adhere to ethical labour practices
6. Due Diligence
AS Controls will exercise due diligence when dealing with suppliers and contractors to:
- Identify and assess potential risks in our supply chains
- Evaluate suppliers’ adherence to ethical labour practices
- Include clauses in contracts that require suppliers to comply with all applicable laws and regulations, including those relating to modern slavery
- Monitor supplier performance and address any concerns promptly
7. Risk Assessment
AS Controls will regularly assess the risk of modern slavery occurring in its business and supply chains. This will involve:
- Identifying sectors or geographical areas that may be higher risk
- Evaluating the types of products or services that may be more susceptible to modern slavery
- Reviewing our business relationships to identify potential risks
8. Reporting Concerns
AS Controls encourages all individuals to report any concerns related to modern slavery, whether within our organisation or in our supply chains. A confidential reporting process is in place, and we will ensure that individuals who raise concerns are protected from retaliation.
9. Training
AS Controls will provide training to relevant employees to ensure they:
- Understand the Modern Slavery Act 2015 and related legislation
- Are aware of the signs of modern slavery and human trafficking
- Know how to report concerns
- Understand the actions AS Controls will take if modern slavery is identified
10. Policy Review
This policy will be reviewed regularly to ensure its effectiveness and compliance with relevant legislation. Any necessary updates will be made and communicated to all relevant parties.
