Anti-slavery and Human Trafficking Policy

Policy Statement
Quentor operates significantly below the MSA-2015 turnover threshold. However, as an ethical operation which does not condone modern slavery in any form, as defined by the Act, we have introduced this Anti-slavery and Human Trafficking Policy to clearly define our position.
 
Quentor strictly prohibits the use of modern slavery and human trafficking in our own operations. We have, and will continue to be, committed to ensuring that modern slavery is not taking place anywhere within our organisation. This policy will be strictly adhered to by all persons working for Quentor or on behalf of Quentor in any capacity, including employees at all levels, directors, officers, apprentices, agency workers, seconded workers, volunteers, agents and contractors.
 
We also take reasonable measures to ensure compliance in our supply chains. We expect that our Suppliers will hold their own Suppliers to the same high standards.
 
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
 
Commitments
We shall be a Company that expects everyone working with us, or on our behalf, to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation
• We will take reasonable measures to ensure similar compliance in our supply chains
• We will expect that our Suppliers will hold their own Suppliers to the same high standards
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf
• Employees must not engage in, facilitate or fail to report any activity that might lead to a breach of this policy
• We will take a risk based approach to our sub-contracted processes and keep them under review. We will assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties
• We will engage with higher risk Suppliers requesting them to comply with the ethos of this policy, encouraging them to take proactive measures to prohibit modern slavery and trafficking in their own operations
• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of Suppliers for their compliance with our policy.
• Consistent with our risk based approach we will require employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with the ethos of this policy.

 
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from ensuring that the breaches are remedied to terminating the relationship. Consideration will be given to the best outcome for those individuals negatively impacted by the breach.