Modern Slavery and Human Trafficking Policy

Introduction

Modern slavery is a serious crime and a breach of basic human rights. It includes slavery, servitude, forced or compulsory labour and human trafficking. These practices remove a person’s freedom for someone else’s gain. Baker Stuart has a zero-tolerance approach to all forms of modern slavery.

We are committed to acting with integrity, being transparent in how we work and making sure our business and supply chain remain free from exploitation.

Scope

This policy applies to everyone who works for or with Baker Stuart. This includes employees, directors, contractors, agency workers, consultants and business partners.

This policy does not form part of any employee’s contract and may be updated at any time.

Definitions

For clarity, the following terms are used throughout this policy:

Modern slavery: The exploitation of a person through coercion, control or abuse of power for personal or commercial gain
Human trafficking: The movement of people for exploitation, using force, fraud or coercion
Forced or compulsory labour: Work performed under threat or without the worker’s consent
Servitude: When a person is forced to live and work under the control of another

Legal Content

Under the Modern Slavery Act 2015, only organisations with an annual turnover of £36m or more are required to publish a slavery and human trafficking statement. Baker Stuart is below this threshold and is not required to publish a statement.

We maintain this policy to set clear expectations for our colleagues and suppliers and to support responsible business practice.

Policy Statement

We are committed to preventing modern slavery in any part of our business. We aim to:

Act ethically and responsibly
Maintain clear systems and controls to prevent exploitation
Work only with suppliers who share our values
Remain transparent in how we manage modern slavery risks
We will not work with any organisation that is knowingly involved in slavery or human trafficking

Related Policies

This policy should be read alongside:

Whistleblowing Policy
Equality and Diversity Policy
Corporate Social Responsibility Policy

These are available on our HR platform and by request from the Operations Manager

Our Supply Chain

Our supply chain is small and mainly UK-based. All suppliers go through a suitability assessment before we work with them. We aim to partner with organisations who operate responsibly and share our values.

Due Diligence

Recruitment and Employment
We take the following steps to ensure safe and fair working practices:

Mandatory training for colleagues involved in HR, recruitment and procurement
A clear recruitment process supported by documented procedures
Use of reputable recruitment agencies with their own human rights standards
Identity checks, right-to-work checks and qualification checks for all new colleagues
Controls to identify potential warning signs, such as shared bank details or addresses
A hybrid onboarding process, with opportunities for face-to-face verification
Support for staff wellbeing, including access to EAP services and employee benefits

Suppliers and Partners
We expect all suppliers to:

Complete a pre-suitability assessment
Confirm that they recognise and prevent modern slavery risks
Co-operate with audits or reviews when needed
Maintain policies that meet current legislation and best practice.

We also:

Carry out checks on higher-risk suppliers
Embed modern slavery considerations into internal audits
Review supplier risks regularly

Risk Assessment

We use our Management Action Log to identify, monitor and manage risks. This includes any potential risk of modern slavery. Risks are reviewed during team meetings, management meetings and our annual away day.

Our aim is to:

Identify potential risks in our business and supply chain
Act quickly where risks are found
Review and reduce risks on an ongoing basis

Responsibilities

The Management Team has overall responsibility for this policy. The Operations Manager oversees its implementation and effectiveness. Managers at all levels must ensure their teams understand and comply with the policy.

All colleagues are responsible for:

Reading and following this policy
Reporting any concerns
Avoiding any activity that may breach the policy

Training

All colleagues involved in recruitment, HR or procurement receive training. New starters learn about modern slavery as part of their onboarding. Training is reviewed each year to ensure it remains current.

Raising Concerns

We encourage colleagues to speak up as early as possible if they have any concerns about modern slavery. Concerns can be raised with:

Your line manager
The Operations Manager
Via the Whistleblowing Policy

Anyone raising a concern in good faith will be supported and will not face any detrimental treatment.

Consequences of Non-Compliance

Employees who breach this policy may face disciplinary action
Suppliers who breach this policy may have their contract suspended or terminated
Serious concerns may be reported to the relevant authorities

Monitoring and Review

This policy is reviewed each year unless an earlier review is required. We monitor its effectiveness through:

Annual policy reviews
Completion of mandatory training
Pre-employment checks
Supplier audits and reviews

This policy has been approved and authorised by:

Name: Wayne Spiller

Position: Managing Director

Date: 17th December 2025

Baker Stuart_Modern Slavery (ANTI SLAVERY AND HUMAN TRAFFICKING) Policy June 2021

Final Audit Report

2021-06-17

Created:

By:

Status:

Transaction ID:

2021-06-17

Maria Pernia m.frutospemia@bakerstuart.com

Signed

CBJCHBCAABAA-Ng856XzcPtoJ6A4P9Iozeu_OCkiBp5p

Created:

2021-06-17

By:

Maria Pernia m.frutospemia@bakerstuart.com

Status:

Signed

Transaction ID:

CBJCHBCAABAA-Ng856XzcPtoJ6A4P9Iozeu_OCkiBp5p