Modern Slavery and Human Trafficking Policy

1.Scope

This policy applies to all colleagues working for BakerStuart 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 andbusiness partners. This policy does not form part of any employee’s contract of employmentand we may amend it at any time.

Under Section 54 of the Modern Slavery Act 2015 some organisations are required to prepare a slavery and human trafficking statement for each financial year, setting out thesteps that the organisation has taken during the year to ensure that slavery and humantrafficking is not taking place in its supply chains or its own business (or setting out that it hastaken no such steps).

However, the duty applies to commercial organisations with a total turnover of at least £36 million per year. “Commercial organisations” that are covered by the duty are body corporates and partnerships that carry on a business, or part of a business, in the UK,supplying goods or services. Therefore, for clarification purpose BakerStuart is not obliged to prepare a slavery and human trafficking statement for each financial year of the organisation, however we have decided to adopt the following policy as part of our ethical approach to business.

2. Purpose and Objectives

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 whichhave in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

BakerStuart has 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, 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 thesame high standards.

3. Related policies.

This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the following workplace policies and procedures which can be found in our Central resources folder (Box.com). You are encouraged to familiarise yourself with the policies detailed below.

  • Whistleblowing policy
  •  Corporate Social Responsibility policy
  •  Equality and Diversity policy
 

If you have any queries about this policy please contact our HR/Operations Manager.

4. Responsibilities.

BakerStuart’s Board of Directors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligation.

The HR/Operations 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 and regular training on it and the issue of modern slavery in supply chains.

5. Compliance with this policy.

You must ensure that you read, understand and comply with this policy.

  1. 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. Youare required to avoid any activity that might lead to, or suggest, a breach of this policy.
  2. You must notify your manager OR the HR/Operations Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
  3. 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 you must notify your manager or the HR/Operations Manager or you may report it in accordance with our Whistleblowing Policy as soon as possible.
  4. 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/Operations 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. BakerStuart is 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 the HR/Operations manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure which can be found in our central resources folder or from the HR department.

This policy is itself kept under continual review.

This Policy Statement has been approved & authorised by:

Name:         Colin Stuart

Position:     Chief Executive Officer

Date:           17th June 2021

Signature:

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

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

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Document created by Maria Pernia (m.frutospernia@bakerstuart.com)
2021-06-17 - 7:42:03 AM GMT- IP address: 109.153.33.212

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Document emailed to Colin Stuart (c.stuart@bakerstuart.com) for signature
2021-06-17 - 7:42:26 AM GMT

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Email viewed by Colin Stuart (c.stuart@bakerstuart.com)
2021-06-17 - 7:46:10 AM GMT- IP address: 82.3.87.40

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Document e-signed by Colin Stuart (c.stuart@bakerstuart.com)
Signature Date: 2021-06-17 - 7:46:15 AM GMT - Time Source: server- IP address: 82.3.87.40

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