Modern Slavery and Ethical Supply Chain Policy
Muraspec is committed to ensuring that it complies with employment law in the regions that it operates, but that also it complies as a minimum with the Ethical Trading Initiative Base Code or equivalent (ETIeq) for both its own business activities and those associated with entities within its supply chains.
Modern slavery is a crime in the UK (Modern Slavery Act 2015) 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.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all our contractors, suppliers and other business partners, and expect that our suppliers will hold their own suppliers to the same high standards.
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.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the Policy
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.
The HR 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 at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate initial training and periodic refresher training on the policy and the issue of modern slavery in supply chains.
Comments, suggestions and queries are encouraged and should be addressed to the HR Manager or Director of Operations and Technology
Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
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.
You must notify your manager or HR as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
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.
If you believe or suspect a breach of this policy has occurred or that it may occur, please notify your manager or report it to the HR Manager.
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 with your manager or the HR Manager.
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 slaver 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 the HR Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance Procedure.
Communication and Awareness of this Policy
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.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Implementation of this policy
The policy requirements will be reflected in the company ISO 9001 management system as part of the strategic risk assessment and assessment of the external context in which the company operates.
The company is a registered member of Sedex, a global platform created with the aim of sharing of ethical supply chain data. Muraspec will share its information with interested parties on request and will allow access to its data for the purposes of second or third party audits.
All suppliers to Muraspec will be required to comply with Muraspec’s policy. As a minimum they will be required to confirm compliance with the ethical trading initiative (ETI) base code or equivalent. Their status regarding ETI base code compliance will be reviewed annually, in the event of persistent or wilful non-compliance suppliers will be removed from the companies approved suppliers listing
Review of the policy
This policy will be reviewed annually within the existing ISO 9001 management review process.
Breaches of this Policy
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.