1.1 This Policy establishes the comprehensive framework through which Salike Limited (the “Company”) prevents, identifies and responds to modern slavery, servitude, forced labour and human trafficking across its operations and supply chains.
1.2 This Policy is drafted in accordance with the Modern Slavery Act 2015 and reflects the Company’s commitment to the highest standards of ethical conduct and corporate governance.
1.3 This document forms part of the Company’s Corporate Governance Framework and shall be read alongside all related policies, including Ethical Practices, Anti-Bribery, and Supplier Governance policies.
1.4 The Company adopts a zero-tolerance approach to modern slavery and shall take all reasonable and proportionate steps to prevent such practices.
2.1 “Modern Slavery” includes slavery, servitude, forced or compulsory labour and human trafficking.
2.2 “Forced Labour” refers to work performed involuntarily under threat or coercion.
2.3 “Human Trafficking” involves arranging or facilitating the travel of a person with a view to exploitation.
2.4 “Supply Chain” includes all suppliers, contractors, subcontractors, agents and partners.
2.5 This Policy shall be interpreted in favour of the higher ethical standard where ambiguity exists.
3.1 This Policy applies to all employees, directors, contractors, consultants and associated persons.
3.2 It applies to all business activities, including procurement, manufacturing, distribution and international trade.
3.3 This Policy applies globally. Where local laws differ, the higher standard shall apply where legally permissible.
4.1 The Board of Directors retains ultimate responsibility for ensuring compliance with this Policy.
4.2 Senior management shall ensure effective implementation, monitoring and enforcement.
4.3 A designated Compliance Officer shall oversee day-to-day compliance and reporting.
4.4 Managers are responsible for ensuring adherence within their operational areas.
4.5 All personnel are responsible for compliance and must report concerns promptly.
5.1 The Company shall adopt a risk-based approach to identifying and mitigating modern slavery risks.
5.2 Risk assessments shall consider:
(a) geographic risk;
(b) sector risk;
(c) supplier risk;
(d) transaction risk.
5.3 Risk assessments shall be documented and reviewed annually or when material changes occur.
6.1 The Company shall conduct due diligence prior to engaging suppliers.
6.2 Due diligence shall include:
(a) verification of supplier identity;
(b) review of policies and practices;
(c) assessment of labour standards;
(d) evaluation of geographic risk.
6.3 High-risk suppliers shall be subject to enhanced due diligence.
7.1 Enhanced due diligence shall be applied where higher risk is identified.
7.2 This includes:
(a) on-site audits where feasible;
(b) independent verification of labour practices;
(c) contractual commitments to ethical standards;
(d) ongoing monitoring and reporting.
8.1 All supplier contracts shall include modern slavery compliance clauses.
8.2 Contracts shall include rights to:
(a) audit suppliers;
(b) request information;
(c) terminate agreements for non-compliance.
8.3 Suppliers must ensure their own supply chains comply with equivalent standards.
9.1 All personnel must report concerns immediately.
9.2 Reports shall be treated confidentially and investigated promptly.
9.3 Whistleblowers shall be protected from retaliation.
10.1 Upon receipt of a report, an initial assessment shall be conducted.
10.2 Where required, a formal investigation shall be initiated.
10.3 Investigations shall include evidence gathering, interviews and documentation.
10.4 Where breaches are identified, corrective actions shall be implemented.
10.5 This may include supplier remediation plans or termination.
11.1 The Company shall provide training to all relevant personnel.
11.2 Training shall cover identification of risks and reporting procedures.
11.3 Training records shall be maintained.
12.1 The Company shall monitor compliance through audits and reviews.
12.2 Internal audits shall be conducted periodically.
12.3 This Policy shall be reviewed annually.
13.1 Breaches may result in disciplinary action, including dismissal.
13.2 Supplier breaches may result in termination of contracts.
13.3 Serious breaches may be reported to authorities.
14.1 The Company shall publish an annual Modern Slavery Statement where required.
14.2 This shall outline actions taken to mitigate risks and ensure compliance.
15.1 This Policy shall be governed by the laws of England and Wales.