1. About Symprex Limited
1.1 Symprex Limited is a limited company registered in England under registration number 03884240.
1.2 We provide software and software as a service to international and UK clients. We have offices in Guildford and do not have offices, premises or employees based outside the UK.
2. Policy statement
2.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and 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.
2.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and human trafficking throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards.
3. About this policy
3.1 The purpose of this policy is to:
(a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
(b) provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
3.2 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
3.3 This policy does not form part of any employee's contract of employment, and we may amend it at any time. It will be reviewed at least annually but also as and when necessary if new circumstances arise that require the policy to be updated.
4. Your responsibilities and how to raise a concern
4.1 You must ensure that you read, understand and comply with this policy.
4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.3 You must notify your manager or otherwise report a concern in accordance with our Whistleblower Policy as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
4.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
4.5 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it promptly with your manager or report it in accordance with our Whistleblower Policy.
4.6 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
5. Our supply chains
5.1 Our zero-tolerance approach to slavery and human trafficking must be communicated to all of our suppliers, contractors and business partners at the start of our business relationship with them.
5.2 As part of our processes for contracting with new suppliers and renewing contracts with existing suppliers, we must where reasonably practical and appropriate:
(a) include specific prohibitions in our contracts with our suppliers against slavery and human trafficking including a right for us to terminate the arrangement if the supplier breaches its obligations under the Modern Slavery Act 2015; and
(b) check that the supplier has in place an appropriate slavery and human trafficking policy and/or has published a current slavery and human trafficking statement if the supplier is required to do so by the Modern Slavery Act 2015.
5.3 We must terminate our relationship with a supplier if they or their contractors and suppliers tolerate slavery or human trafficking in any part of their business or supply chains.
6. Responsibility for the policy
6.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
6.2 The Human Resources Director 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.
6.3 Management at all levels in Symprex 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.
6.4 Comments, suggestions and queries on this policy are encouraged and should be addressed to the compliance manager.
7. Training
7.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
7.2 This policy must be made available to all employees and staff in the Employee Policy Pack.
8. Breaches of this policy
8.1 Any employee who breaches this policy will face disciplinary action, which in serious cases could result in dismissal.
Last updated: 23 October 2024