Modern Slavery and Human Trafficking Policy

Sussex Biologicals Limited are committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices. Accordingly, Sussex Biologicals will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers employing or utilising child labour or forced labour.

Rationale

Human trafficking and slavery are crimes under UK and international law. This policy statement thus defines Sussex Biologicals commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Sussex Biologicals will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Sussex Biologicals has appointed its HR Manager as its compliance officer (its Anti-Slavery and Human Trafficking Officer) and will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by it “Suppliers”) worldwide.

All Suppliers/contractors are therefore required to adhere to the following definitions:

Human Trafficking

The recruitment, transportation, transfer, harbouring or receipt of persons, by means of threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced Labour

All work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.

Harmful Child Labour

Consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Requirements for Suppliers

Will not use forced or compulsory labour, ie any work or service that a worker performs involuntarily, under threat of penalty;
Will ensure that the overall terms of employment are voluntary;
Will comply with the minimum age requirements prescribed by applicable laws;
Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;
Will abide by applicable law concerning the maximum hours of daily labour;
Will not engage in any practice of slavery, servitude, forced labour, compulsory labour
Will ensure that any sub-contractors or suppliers also adhere to these requirements.

Certification

Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

Audits

Upon request Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Sussex Biologicals. Sussex Biologicals may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting

Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting the HR Manager (in his capacity Sussex Biologicals Anti-Slavery and Human Trafficking Officer).

Consequences

Sussex Biologicals takes any breach of this Policy extremely seriously.

Suppliers who are found to be or have been engaging in human trafficking and slavery or who refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract terminated immediately, without compensation.

If a Supplier to Sussex Biologicals is found in violation of this policy, Sussex Biologicals will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer (HR Manager) shall determine to be necessary to address the violation and seek to prevent its reoccurrence.

This Modern Slavery and Human Trafficking statement will be regularly updated as necessary.