Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers, including children. It can take various forms, such as slavery, forced or compulsory labour and human trafficking.

AC PLC has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

AC PLC expects the same high standards from its suppliers, sub-contractors and other business partners. As part of the contracting processes, specific prohibitions against the use of modern slavery is included. AC PLC expects that its suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment.

In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, AC PLC accepts that it has a responsibility through practical and reasonable due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
This policy applies to all individuals working for, or on behalf of, AC PLC in any capacity, including employees, directors, officers, agency workers, volunteers, agents, sub-contractors, consultants and business partners.

The Board of Directors has overall responsibility for ensuring that this policy complies with the company’s legal and ethical obligations. The AC PLC H&S Managers have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the company’s business or supply chains.

Departmental Managers are responsible for ensuring that those reporting to them understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of the company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the company or under the company’s control.

If you believe, or suspect a breach or a conflict with this policy has occurred or may occur, you must notify your line manager. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the Government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

AC PLC 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. The company is committed to ensuring no one suffers any detrimental treatment or victimisation because of reporting in good faith, its suspicion that modern slavery is, or may be, taking place in any part of its business or in any of its supply chains.

Regular training on this policy, and on the risk, that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

AC PLC’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

AC PLC may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

This policy will be communicated to all employees and organisation’s working on our behalf, and displayed on our intranet and is available to defined interested parties.

This policy will be reviewed annually or sooner by senior management to ensure its suitability. Where necessary it will be amended, reissued and communicated to all employees and people working on its behalf.


– Andrew C Laing

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