1. Purpose of Document
The purpose of this document is to provide a definition of the Anti-Slavery and Human Trafficking Policy for Cortland in the UK.
2. Policy Statement
2.1 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 which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
2.2 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 as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
2.3 This policy applies to all persons:
(a) working for, or on our behalf, in any capacity, including associates at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, and agents; and
(b) our contractors, external consultants, agencies, third-party representatives, and business partners.
3. Responsibility for the Policy
3.1 Cortland’s Europe Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
3.2 The Director of Construction and Talent Team have 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.
3.3 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.
3.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed with the Talent Team.
4. Compliance with the Policy
4.1 You must ensure that you read, understand, and comply with this policy.
4.2 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.
4.3 You must notify the Talent Team as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
4.4 If you believe or suspect a breach of this policy has occurred or that it may occur, you must speak to your Line Manager or Talent Team. Alternatively, you could confidentially approach the Anonymous Helpline via +1 404 978 1193 or over email via firstname.lastname@example.org.
4.5 If you are unsure about whether a particular act, the treatment of workers, or working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, you should immediately raise it with your line manager or the Talent Team.
4.6 Cortland aims 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 slavery of any form is or may be taking place in any part of our business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
4.7 If you believe that you have suffered any such treatment, you should inform the Talent Team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our Company Handbook.
5. Communication and Awareness of the Policy
5.1 Training on this policy, and the risk our business faces from modern slavery in our supply chains, forms part of the induction process for all associates who work for us, and regular updates will be provided as necessary.
5.2 Our zero-tolerance approach to modern slavery must be communicated to all contractors, third-party suppliers and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
6. Breach of the Policy
Any associate who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Any organisations working on our behalf who breach this policy faces termination of our working relationship.