Anti-Slavery and Human Trafficking Policy

PURPOSE

At Hunter Engineering Services, we are dedicated to uphold the highest ethical standards in all aspects of our business operations and supply chain. We are a small company but are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains. Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015 and the Human Trafficking and Exploitation Act (Scotland) 2015.

To achieve this, we have developed this anti-slavery and human trafficking policy. It applies to all persons working for us or on our behalf in any capacity, including employees at all levels, agency workers, seconded workers, contractors, external consultants, third-party representatives and business partners.

1. Compliance with Laws and Regulations: We will comply with all applicable laws and regulations related to slavery, forced labour, human trafficking and child labour including but not limited to the Modern Slavery Act, and in Scotland, where our company is located, the Human Trafficking and Exploitation Act (Scotland) 2015 as well as international conventions and protocols.
2. Zero Tolerance: We have a zero-tolerance approach to slavery, forced labour, human trafficking and child labour. These practices will not be tolerated within our company and our supply chain.
3. Supplier Due Diligence: We will conduct thorough due diligence on our suppliers to ensure that they share our commitment to combating slavery and human trafficking. This includes assessing their policies, procedures, and practices relating to labour and human rights.
4. Suppliers Audits and Assessments: We will periodically audit and assess our suppliers to verify their compliance with anti-slavery standards. These assessments may include observations from on-site installation visits, documentation reviews, and form part of our procurement process.
5. Risk Assessment and Mitigation: We will conduct risk assessments to identify high-risk areas within our supply chain where there may be a greater likelihood of slavery or human trafficking. We will implement appropriate mitigation measures to address these risks.
6. Supplier Collaboration: We will collaborate with our suppliers to address any identified non-compliance with our anti-slavery standards. This may include collaboration on actions required to prevent this and manage the risk. We expect high standards from all of our subcontractors, suppliers and other business partners and have made this a contractual term in our agreements with significant suppliers wherever possible.
7. Whistleblowing Protection: We will establish a mechanism to encourage the reporting of concerns relating to slavery, forced labour, human trafficking and child labour. We will protect whistleblowers from retaliation and ensure that their concerns are promptly and thoroughly investigated. Any issues relating to this will be reported directly to the Managing Director. If appropriate an external review will be undertaken including a recommendation on any actions required in accordance with our Whistleblowing Procedure.
8. Transparency and Reporting: We are committed to transparency in our efforts to combat slavery and human trafficking. This will be included in our company risk register identifying the level of risk, mitigation and actions required.
9. Employee Awareness and Training: We will provide training to our employees to raise awareness about slavery, forced labour, human trafficking and child labour. This training will empower employees to identify and report any suspected cases within the company or supply chains.
10. Continuous Improvement: We will continuously review and improve our anti-slavery policies and practices based on the evolving understanding of the risks and challenges associated with modern slavery. We will also engage with clients, stakeholders, industry peers, suppliers, and experts to share best practice and driven collective action.
11. Policy Review: This policy will be updated on an annual basis to ensure that it is current and complies with any changes in legislation.

RESPONSIBILITY FOR THE POLICY

The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all staff comply with it.

The Managing Director has primary and day-to-day responsibility for implementing this policy, including reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective in countering modern slavery.

COMPLIANCE WITH THE POLICY

All employees must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Although employees should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains direct to the Managing Director, staff are also encouraged to discuss a specific matter as they feel appropriate.

COMMUNICATION AND AWARENESS OF THIS POLICY

The policy will be updated on an annual basis and staff will be consulted and asked for input to inform the contents. The policy will be filed on the CRM system and appropriate support material will be provided. Staff will be asked to confirm that they have reviewed the policy and completed any associated training.

Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

Our focus is on continuous improvement through learning, training and prevention rather than disciplining staff unless there is no option.

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

By adopting this anti-slavery policy, we are committed to playing an active role in eradicating slavery and human trafficking. We will work diligently to ensure that our operations and supply chain are free from these egregious violations of human rights.