Anti-Slavery & Human Trafficking Policy

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 facilities 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.

 

Policy Statement

 

This policy applies to all persons working for us on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Argentium Global Sales 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 that our suppliers will hold their own suppliers to the same high standards. 

The directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Your manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

Management 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 in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to your manager.

 

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery.

  • We have zero-tolerance approach to modern slavery in our organisation and our supply chains.

  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

  • We will communicate this policy to staff and provide training as appropriate.

  • We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. 

  • Consistent with our risk-based approach we may require:

    • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Ethics Policy.

    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Ethics Policy.

  • As part of our ongoing risk assessment and due to diligence processes, we will consider whether circumstances warrant us carrying out audits of the suppliers for their compliance with our Ethics Policy.

 

If we find that their individuals or organisations working on our behalf have breached this policy, we will ensure that we appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.