1 POLICY STATEMENT
1.1 This is the anti-slavery policy of CP Plus Limited (trading as GroupNexus) and all UK entities that form part of the same group or are otherwise affiliated or associated from time to time – hereinafter collectively referred to as “GroupNexus” (and “we”, “us” and “our”).
1.2 Modern slavery is a crime and a violation of fundamental human rights. GroupNexus recognises that this 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.
1.3 GroupNexus is committed to acting ethically and with integrity in all its business dealings and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business operations or in any of GroupNexus’s supply chains.
1.4 GroupNexus is also committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015 (the “Act”). It expects the same high standards from all of its suppliers, contractors and other business partners. As part of GroupNexus’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in this policy.
2.1 The purpose of this policy is to:
2.2 This policy applies to all persons working for GroupNexus or on its behalf in any capacity, including employees at all levels, directors, officers, frontline staff, agency workers (including those engaged by suppliers), volunteers, interns, agents, suppliers, contractors, external consultants, third-party representatives and business partners (collectively, “Associated Persons”).
2.3 The board of directors of each relevant GroupNexus entity has overall responsibility for ensuring this policy complies with GroupNexus’s legal and ethical obligations, and that all those under its control comply with it.
2.4 All GroupNexus managers are responsible for ensuring that this policy and GroupNexus’s zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with this policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.
2.5 Management has 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.
2.6 We may amend this policy from time to time.
3.1 All Associated Persons must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.2 All Associated Persons are required to raise any concerns about any issue or suspicion of modern slavery in any part of GroupNexus’s business or supply chains of any supplier tier at the earliest possible stage.
3.3 GroupNexus 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. GroupNexus is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of GroupNexus’s supply chains. “Detrimental treatment” includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
3.4 If any GroupNexus staff member believe they have suffered any detrimental treatment referred to at paragraph 3.3 , the individual should inform either their manager or the HR Department without delay. If the matter is not remedied, the GroupNexus staff member should raise it formally in accordance with the grievance procedure, which can be found in the GroupNexus employee handbook.
3.5 As part of our due diligence process, all suppliers/sub-contractors must complete a questionnaire relating to quality control (covering the commitment under this policy) and their suitability as supplier/sub-contractor of GroupNexus is assessed based on this questionnaire prior to award of contract. Where GroupNexus (acting reasonably) considers it necessary, a GroupNexus representative may visit a supplier/sub-contractor to ensure that it is completely satisfied with the processes and procedures in place and in accordance with the supplier/sub-contractor’s policy. Those responsible for setting up contracts with suppliers/sub-contractors are to utilise the questionnaire and forward onto GroupNexus’s designated manager of the Approved Supplier/Sub-contractor Register who will be responsible for assessing the suppliers/sub-contractors annually for their commitment to its policies.
3.6 GroupNexus may from time to time require suppliers/sub-contractors to execute a letter in the form prescribed in Annex A to this policy, particularly in the following circumstances:
4.1 Reporting concerns about modern slavery is a vital step in protecting vulnerable individuals and upholding ethical and legal standards within our organisation and wider society. As mentioned at paragraph 1.2 , modern slavery can take many forms and often goes unnoticed without the vigilance and courage of those who speak up.
4.2 By reporting suspected cases, Associated Persons help ensure that:
4.3 If any Associated Person has any reason to believe or suspect that a breach of this policy has occurred or that it may occur, they are required to, as soon as reasonably practicable:
4.4 If any Associated Person is unsure about whether any particular act, treatment of workers more generally, or their working conditions within any tier of GroupNexus’s supply chains constitutes a form of modern slavery, this should still be raised in accordance with paragraph 4.3 .
4.5 In addition to the reporting mechanisms outlined in paragraph 4.3 , Associated Persons can also raise concerns confidentially by contacting the Modern Slavery Helpline on 0800 0121 700 or at www.modernslaveryhelpline.org. However, Associated Persons are encouraged to conduct initial reporting pursuant to paragraph 4.3 .
4.6 All reports are taken seriously and investigated promptly, with appropriate action taken to address any issues identified. Speaking up plays a crucial role in ensuring that our workplace and supply chains remain free from modern slavery and exploitation.
5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and refresher training will be provided as necessary. GroupNexus line managers are responsible for ensuring that all employees have completed any such training.
5.2 All GroupNexus contract managers and heads of departments who are responsible for procurement of goods and/or services must ensure that this policy and GroupNexus’s zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners during the procurement process and/or at the outset of each business relationship, and reinforced as appropriate on an ongoing basis.
5.3 All contract managers and heads of departments are also responsible for ensuring that adequate safeguards are implemented when engaging or contracting with third parties. Such safeguards may include incorporating contractual obligations to comply with the Act or requiring the execution of a compliance letter, as appropriate.
6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with suppliers, contractors or other business partners if they breach this policy.
Appointment: Operations Director
Annex A Template compliance letter
[NAME OF SUPPLIER] [ADDRESS LINE 1] [ADDRESS LINE 2]
Dear Sir/Madam Modern Slavery Act 2015 (the “Act”) We refer to the agreement between you and us for [DESCRIPTION OF AGREEMENT] dated [DATE] [and amended on [DATE(S)]] OR as amended from time to time] (the “Agreement”), a copy of which is annexed to this letter. We have a zero-tolerance approach to modern slavery, which is a crime and a violation of fundamental human rights. We recognise this 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. We are committed to acting ethically and with integrity in all our business dealings and relationships with suppliers.
The purpose of this letter is to supplement the Agreement with the terms set out below relating to compliance with the Act. In performing your obligations under the Agreement, you agree:
The parties intend this letter to be legally binding. To the extent of any conflict between the terms of the Agreement and this letter, the terms of this letter shall prevail.
This letter and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the law of England and Wales.
Each party irrevocably agrees that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this letter or its subject matter or formation.
Please acknowledge receipt and acceptance of this letter by signing, dating and returning a copy of this letter. This letter has been executed as a deed and is delivered and takes effect on the date of the signature of the last signatory.
Executed as a deed by CP PLUS LIMITED acting by the following authorised signatories:
………………………………………….. [NAME OF FIRST DIRECTOR] Director
………………………………………….. [NAME OF SECOND DIRECTOR] Director
We acknowledge receipt and accept the contents of this letter. [Executed as a deed by [NAME OF SUPPLIER] acting by the following authorised signatories:
………………………………………….. [NAME OF FIRST DIRECTOR] Director
………………………………………….. [NAME OF SECOND DIRECTOR] Director
OR [Executed as a deed by [NAME OF SUPPLIER] acting by:
………………………………………….. [NAME OF DIRECTOR] Director
In the presence of: Signature of witness: ………………………………………….. Name of witness: ………………………………………….. Address of witness: ………………………………………….. Occupation of witness: …………………………………………..]
- set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
- provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
- where the supplier/sub-contractor has not completed the questionnaire mentioned at paragraph 3.5 ;
- where the supplier/subcontractor has completed the questionnaire, but the responses to the questionnaire are deemed unsatisfactory to GroupNexus;
- where the contract between GroupNexus and the supplier/sub-contractor does not include an obligation to comply with the Act; an
- where GroupNexus considers that the anti-slavery provisions in its contract with the supplier/sub-contractor are inadequate.
- individuals at risk are identified and supported;
- the organisation remains compliant with the Act and related ethical obligations;
- unsafe or exploitative practices are stopped before further harm occurs; and
- a culture of integrity, transparency and accountability is maintained.
- If they are a GroupNexus staff member: (i) notify either their line manager or the HR department; or (ii) report their concerns through the whistle-blowing procedure set out in the GroupNexus employee handbook;
- If they are any other Associated Persons: notify a senior GroupNexus manager, who may escalate the matter to the Operations Director where appropriate
- to comply with (and procure that your own suppliers, sub-contractors and other participants in your supply chains comply with) the Act and the GroupNexus Anti-Slavery Policy (as amended from time to time and available upon request);
- to implement appropriate due diligence procedures for your own suppliers, sub-contractors and other participants in your supply chains to ensure that there is no slavery or human trafficking;
- to notify us and confirm the same promptly in writing immediately upon discovering any breach or potential breach of the Act or any actual or suspected slavery or human trafficking in your supply chains; and that a breach of the terms of this letter shall entitle use to terminate the Agreement with immediate effect upon notice.