Modern slavery policy
1. Overview and how we define Modern Slavery
1.1 Modern slavery is a term used to describe serious forms of exploitation and includes:
- Human trafficking
- Forced labour
- Bonded labour
- Debt bondage
- Servitude
- Child labour
- Slavery and slavery-like practices
- Exploitation through coercion, intimidation or abuse of vulnerability
1.2 We conduct our business fairly, ethically and with respect to fundamental human rights. We are committed to the prevention of all forms of Modern Slavery, both in our business and in our supply chains. We will not tolerate it.
1.3 You must read and comply with this policy if you work for, or on behalf of us in any capacity including as: an employee, director, officer, worker, consultant, volunteer, supplier or service provider.
1.4 Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and us. It could also involve other legal steps being taken against you.
1.5 Our Anti-Slavery Officer (‘ASO’) is Rob Wilkinson. They are responsible for this policy.
1.6 If you are an employee, this policy does not form part of your employment contract, and we may update it at any time.
2. Preventing Modern Slavery in our business
2.1 We carry out appropriate checks on all employees, recruitment agencies and suppliers, so that we know who is working for us or on our behalf.
2.2 We give every employee a written employment contract, and he or she is paid in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks and holidays.
2.3 This policy applies to:
- Directors
- Employees
- Consultants
- Contractors
- Agency workers
- Volunteers
- Suppliers
- Service providers
- Sub-contractors
- Any individual or organisation acting on behalf of GRC Hub
3. If you are one of our Suppliers
3.1 If you supply us with goods or services, you must assess your business and supply chains and confirm to our ASO that you:
- Comply with your legal obligations, in relation to Modern Slavery; and
- Are committed to ensuring there is no Modern Slavery taking place in your business, or in any of your supply chains.
3.2 If you breach this policy, or are found to have Modern Slavery in your business, or knowingly in your supply chain, we may terminate our contract with you.
4. If you are an Employee or a Worker providing services for us
4.1 You must immediately report any suspicions of Modern Slavery in our business or supply chains to our ASO. Our ASO will investigate and report to our Board of Directors within a reasonable time, on actions which may require to be taken.
4.2 You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately tell our ASO and, if you are an employee, refer to our Grievance and Whistleblowing Policies.
5. Employment practices
5.1 Compliance with Legislation
- Employment legislation
- Equality legislation
- Health and safety requirements
- Immigration requirements
- Human rights obligations
5.2 Freely Chosen Employment
- Enter employment voluntarily
- Leave employment voluntarily
- Terminate employment in accordance with contractual terms and applicable legislation
5.3 Recruitment Practices
- Verify the identity and legal right to work of all personnel
- Conduct appropriate due diligence on recruitment agencies
- Use reputable recruitment providers where appropriate
5.4 Working Hours
5.5 Freedom of Movement
- Retain passports
- Confiscate identification documents
- Withhold immigration documentation
- Restrict lawful movement
5.6 Freedom of Association
- Join trade unions
- Decline trade union membership
- Participate in lawful representative bodies
- Raise employment concerns without fear of retaliation
5.7 Equality and Non-Discrimination
5.8 Dignity and Respect
- Violence
- Threats
- Harassment
- Bullying
- Intimidation
- Coercion
- Abuse
5.9 Child Labour
6. Supply chain expectations
- Comply with all applicable employment laws
- Prohibit forced labour and human trafficking
- Prohibit child labour
- Prohibit worker-paid recruitment fees
- Prevent discrimination and harassment
- Maintain lawful working conditions
- Respect freedom of movement and freedom of association
- Operate ethical employment practices
7. Reporting concerns
Any person associated with GRC Hub who suspects modern slavery, exploitation or unethical labour practices must report their concerns immediately to the Anti-Slavery Officer.
- Employees
- Contractors
- Suppliers
- Partners
- Third parties
8. Whistleblowing protection
GRC Hub encourages individuals to raise genuine concerns in good faith.
9. Investigation and remedation
Where modern slavery concerns are identified, GRC Hub will:
- Investigate allegations appropriately
- Take corrective action where required
- Cooperate with relevant authorities
- Review supplier relationships where necessary
- Implement measures to prevent recurrence
10. Training and Awareness
All personnel must familiarise themselves with this policy.
- Modern slavery indicators
- Reporting mechanisms
- Ethical recruitment practices
- Supply chain responsibilities
11. Monitoring and review
GRC Hub will review this policy periodically to ensure continued compliance with legal requirements and good practice.
- Employee awareness
- Supplier engagement
- Incident reporting
- Internal governance reviews
12. Questions
if you have any questions around how GRC Hub ensures fair working practices please contact us.
Version Control
- First Release: June 2025
- Review and Adjustment: August 2026