ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

DEFINITIONS

Modern slavery is a term used to encompass the severe exploitation of other people for personal or commercial gain.  Human trafficking is a form of modern slavery, via the process of trapping people using violence, deception or coercion and exploiting them for personal or commercial gain.  Modern slavery is a crime and a violation of fundamental human rights.

PURPOSE

At W&M Wholesale Limited, we strictly prohibit the use of modern slavery or human trafficking in any aspect of our business, or supply chains.  This applies to all persons working for, or alongside, W&M Wholesale Limited, including employees, directors, agency workers, volunteers, agents, contractors, and suppliers.  At W&M Wholesale limited, we wholly believe in “doing the right thing”: we always act with honesty and integrity, and we treat others as we expect to be treated ourselves. This is our expectation of all stakeholders at W&M Wholesale Limited, internal, and external.

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:

Maintain a zero-tolerance approach to modern slavery within W&M Wholesale Limited and our supply chains.

The detection, reporting and prevention of modern slavery in any part of our Company or its supply chain is the responsibility of all those working for us, or on our behalf.  Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.

We are committed to engaging with our stakeholders to address the risk of modern slavery in our operations and the supply chain.

If we identify a breach of this policy, we will ensure to take appropriate action. This may range from remediation to termination of relationships.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

W&M Wholesale Limited’s Anti-Slavery Policy identifies our commitment to acting ethically and with integrity in all business relationships and implementing and enforcing effective systems and controls to prevent modern slavery and human trafficking.

  • Build long-standing relationships with local suppliers and make clear our expectations of required behaviour.
  • Have a policy of “knowing our customer” to ensure that we are contracting with appropriate businesses.
  • Ensure we execute robust recruitment checks in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above.
  • Pay our staff in accordance with legal requirements and reviewed frequently.
  • Monitor and manage areas of potential risk to our Company and its supply chains.
  • Adopt a zero-tolerance approach to slavery and human trafficking throughout the organisation and our supply chains.

RESPONSIBILITIES

The Company, our managers, directors, and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.  Everyone must observe this Policy and be aware that ‘turning a blind eye’ is unacceptable, a breach of our employee code of conduct, and simply not an option.  As a Company, we will:

  • Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
  • Examine our stakeholders and be transparent with key suppliers our expectations.
  • Make appropriate legislative checks on all employees, suppliers, agents, contractors, and volunteers to ensure we know transparently who we have working for the Company.
  • Ensure the grievance policy is known across all staff.
  • Promote awareness to our colleagues so they understand we foster their welfare.

DECLARATION

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking policy.

 

Anthony Wallett | Director