This statement is applicable to all subsidiaries of PFF Group: PFF Health Limited; PFF Packaging Limited
Aims of this policy
This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.
The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative.
We expect all who have; or seek a business relationship with the company to familiarise themselves with this policy and to act in a way that is consistent with its values.
We will strive to only do business with organisations who fully comply with this policy or those who are taking verifiable steps towards compliance.
This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).
What do we mean by modern slavery?
Modern slavery can take many forms. It is a complex and multi-faceted problem. The MSA covers four key criminal activities:
Slavery: where ownership is exercised over an individual
Servitude: involves the obligation to provide service imposed by coercion
Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them
Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to:
Child labour: whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development. This is covered under our Ethical Code of Conduct Policy.
All forms of modern slavery have in common the deprivation of a person’s liberty by another, to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspect of our business and business relationships.
How we seek to embed our anti-slavery policy in practice
To underpin our policy commitments, we aim to implement the following measures over the course of the next financial year:
• We will conduct risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery so we can focus our efforts on those areas most ‘at risk’. Imported goods from sources outside the UK and EU are potentially more at risk for slavery/human trafficking issues.
• Where appropriate, as informed by our risk assessment, we will engage directly with suppliers in respect of our anti-slavery policy to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses and supply chains, and, where appropriate, agree how such measures should be enhanced.
• Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour and the use of child labour in line with this policy. We also make provision for our contracted suppliers to hold their own suppliers to the same standards we also reserve the right to terminate any contractual arrangement if there is a breach of this policy.
Responsibility for this policy
The board of directors has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
The Group Quality & Compliance Manager will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
All Directors are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
Communication and employee awareness training
The Group Quality & Compliance Manager will ensure that this policy is communicated to all relevant staff and that they understand the responsibility applicable to their role. This communication will form part of the on-the-job training for relevant job roles.
In addition, all employees will receive information on the broader issues of modern slavery as part of HR induction, to assist them in appreciating the extent of the problem of modern slavery and identify individuals/areas of the business that may be at risk from practices of modern slavery.
Breaches of this policy
Any breaches of this policy will be taken seriously and dealt with on a case-by-case basis.
The breach of this policy by an employee, director or officer of the company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to our disciplinary procedure.
Everybody to whom this policy applies to will be expected to co-operate fully in any investigation into suspected breaches of this policy or any related processes or procedures.
If any part of this policy is unclear, clarification should be sought from the Group Compliance Manager.
Status of this policy
This Anti-slavery policy will be reviewed by the Company’s board of directors on a regular basis at least annually.
This policy does not give contractual rights to company employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.
Links to other related documents:
Ethical Code of Conduct Policy
Supplier Ethical Self-Assessment Questionnaire
Version 01
HRPOL/DOC/06
December 2020
