Captrad Limited

Anti-Slavery Policy

Current policy: CT/A.S.Policy/AUG2024

Captrad Limited is committed to acting ethically and with integrity in all business dealings and relationships. We operate a zero-tolerance approach to modern slavery and maintain systems and controls designed to prevent it taking place within our UK operations or supply chains.

Download the current anti-slavery policy

1. Policy statement

Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour and human trafficking. Captrad Limited is committed to transparency in its business and supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from suppliers, contractors and other third parties. As part of our contracting processes, we expect suppliers to hold their own suppliers to the standards set out in this policy.

2. Policy application

This policy applies to all persons working for Captrad Limited or on our behalf, including employees, directors, officers, agency and seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. It does not form part of an employee’s contract of employment and may be amended by the Company.

3. Responsibility for the policy

The Director has overall responsibility for ensuring that this policy complies with our legal and ethical obligations. Directors are responsible for implementing it, monitoring its effectiveness, responding to policy queries and auditing internal controls and procedures that help counter modern slavery.

Management is responsible for ensuring those reporting to them understand and comply with the policy, and receive appropriate training on modern slavery risks in supply chains.

4. Compliance and reporting concerns

All staff and third parties must raise concerns or suspicions of modern slavery in any part of Captrad Limited’s business or supply chains as early as possible. Concerns should be reported to a manager, the UK Legal Department or a senior Captrad point of contact.

Managers involved in procuring goods or services must communicate this policy and Captrad’s zero-tolerance approach to third parties during procurement and at the outset of each business relationship.

5. Breaches of this policy

An employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Captrad Limited may terminate its relationship with other individuals or organisations working on its behalf if they breach this policy.

Signed: Phil Capstick, Director