Modern Slavery
and Human Trafficking Policy

This policy has been written to work alongside our Modern Slavery and Human Trafficking statement  in accordance with Section 54(1) of the Modern Slavery Act 2015.

This policy may be used to provide guidance for employees and our supply chain to ensure they are operating in accordance with the statutory rules detailed within the Modern Slavery Act 2015.

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.

Petit Forestier UK Ltd. recognises that is has a responsibility to take a robust approach to slavery and human trafficking within its operations and supply chains.

Our supply chain

Petit Forestier recognises the responsibility that we have to work with all parties in our business and supply chain to ensure that those within it are treated fairly, humanely and with respect. We believe this means ensuring that workers are not exploited or subject to unsafe or inhuman working conditions, that child labour is not used and that our staff should be free to raise any concerns or suspicions they have so that they can be investigated and acted upon. Staff are encouraged to raise any concerns with their managers or through our confidential whistleblowing procedure.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our statement reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not place anywhere in our supply chain.

To ensure those in our supply chain and contractors comply with the values described in our Modern Slavery and Human Trafficking  statement, we require them to  confirm they have in place their own equivalent statement of at least the same standard and provide us with a copy of such code. Key provisions require our suppliers to agree that they will not use child labour, not allow inhumane treatment, not practise discrimination and not allow excessive hours of work.

Our people 

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and confirm that the following practises are in place.

• No forced labour or human trafficking is practised and employment is freely chosen.
• Evidence of having a right to live and work in the UK is checked  before any employment commences.
• Working conditions are safe.
• Working hours are not excessive or forced.
• A fair wage is paid.
• No child labour is exploited.
• No harsh, cruel or degrading practises are allowed.
• No discrimination is practised.
• On joining an induction is given to all employees, which covers the essential policies and information in relation to policies and procedures such as whistleblowing.

We have in place the following accessible appropriate policies and practises to enable our staff to bring concerns to our attention.

•  This policy
•  Code of conduct
•  Grievance policy
•  Dignity in the workplace policy
•  Health and safety policies
•  Whistleblowing policy
•  Confidential email address

Training

We are committed to ensuring that all employees within our business are trained to ensure they are operating within the guidelines of our Modern Slavery and Human Trafficking policy, whilst carrying out their duties including the recruitment of new employees. Training is available from the Human Resources department to ensure compliance with our policy.

Guidance may also be given to our supply chain where concerns have been highlighted.

Purpose

The purpose of this policy is to encourage staff that have any concerns about breaches of the Modern Slavery Act 2015 to voice their concerns to the Company promptly and properly. The Company is committed to maintaining the highest standards of integrity, honesty and professionalism in the workplace. The policy applies to employees [suppliers, contractors, volunteers] and workers at all levels of the Company. This policy reflects legal obligations but does not form part of your contractual terms of employment and may be amended or replaced at any time at the Company's discretion.

The policy sets out a procedure which it encourages staff to follow if they wish to report any matter. The Company understands that staff may not always feel comfortable discussing their concerns internally but reassures all members of staff that any matter raised will be treated with proper consideration. Staff should be reassured that no person who makes a bona fide report, by following this procedure, will be subjected to any detriment as a result of doing so. Should any person believe they have suffered any detriment by invoking the procedure they should inform the Human Resources Department immediately.

Procedure

The Company encourages you to raise any concern in the first instance with [your line manager] either orally or in writing. If [the line manager] feels unable to deal with your concern they may refer it to the appropriate director or the Human Resources Department. If [your line manager] is the subject of your complaint or you feel unable to discuss it with them for any other reason (perhaps because the matter is too serious), you should raise the issue with the Human Resources Department.

A meeting will be arranged as soon as is reasonably possible to discuss your concern with you. Where appropriate, you may be asked to provide information and evidence substantiating your concern. You are entitled to bring a colleague or union representative to any meeting in connection with this policy. Both you and your colleague must respect the confidentiality of the disclosure and any matter in relation to it under this policy.

You will be provided with a copy of any formal note taken of the meeting and you will be advised as to how the Company intends to proceed. You will also be advised of the likely timescale of any further investigation which may be necessary.

The Company understands the desire, in some cases, for anonymity. However, where a person making a disclosure wishes to remain anonymous this is likely to impede any investigation. It is, of course, preferable to disclose a concern anonymously than not to disclose it at all but members of staff are encouraged to disclose matters openly. The Company will endeavour to ensure that your identity is kept secret save where it is necessary to disclose this.

You will be advised of the outcome of the meeting and any investigation, although it may be necessary to keep some matters confidential from you (for example, where any disciplinary action has been taken against another member of staff).

In the event that you feel the matter has not been resolved satisfactorily, you may pursue the concern with the Managing Director.

The Company recognises there may be matters that cannot be addressed internally and which should be referred to external authorities, such as UK Border agency or the Home Office. Where this becomes necessary the Company may make such a referral without your express consent.

Save in exceptional circumstances you should not disclose your concerns outside the Company unless you have first provided the Company with the opportunity to address the problem.