Anti-Slavery and Human Trafficking Policy  
Revision No.1  

Ref: ISO 9001


Procedure Review: Annually Authorised by: L. de Souza
Last Reviewed: January 2022




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 (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Graham Smith UK (LTD) has a zero-tolerance approach to modern slavery within its business and supply chains.

This policy applies to all persons:

(a) working for the company, or on our behalf, in any capacity, including

employees at all levels, directors, officers, agency workers, seconded

workers, volunteers, interns and agents (“Company Staff”); and

(b) our contractors, external consultants, agencies, third-party representatives,

and business partners (“Suppliers”).


Graham Smith UK (LTD) is committed to:

(a) acting ethically and with integrity in all our business dealings and


(b) implementing and enforcing effective systems and controls to ensure

modern slavery is not taking place anywhere in our business or in any of our

supply chains; and

(c) ensuring there is transparency in our approach to tackling modern slavery in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all our Suppliers. As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our Suppliers will hold their own suppliers to the same high standards.


Sound business relationships with Suppliers are essential in order to maintain a dependable, competent source of supply for the uninterrupted flow of quality goods and services to the company.

Purchasing is the primary source of contact and channel of communication with all Suppliers. Honesty, integrity, confidence and tact should be employed by all purchasing staff to establish and maintain mutually satisfactory bonds of respect and understanding with Suppliers. These relationships will enable purchasing staff to enhance the reputation of the company in the course of their duties, building goodwill that will serve the company well in all its activities.


To purchase from qualified suppliers, ISO 9001 2015 requires us to maintain lists of approved suppliers for products we purchase regularly. The company must check all suppliers for compliance with quality assurance standards, and audit them to find out if they qualify.
To assess a supplier, the company can rely on third-party certification that the supplier is complying with required quality standards. For non-certified suppliers, companies can require that the supplier become certified.


Modern slavery may be found in:

(a) our business, for example our cleaning and catering workforce;

(b) our supply chains;

(c) outsourced activities, particularly to jurisdictions that may not have

adequate modern slavery safeguards.

There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

(a) The person is not in possession of their own passport, identification or travel documents.

(b) The person is acting as though they are being instructed or coached by

someone else.

(c) The person allows others to speak for them when spoken to directly.

(d) The person is dropped off and collected from work.

(e) The person is withdrawn or appears frightened.

(f) The person does not seem to be able to contact friends or family freely.

(g) The person has limited social interaction or contact with people outside of

their immediate environment.

The above list is not exhaustive. A person may display several of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking


The Management has overall responsibility for ensuring this policy complies

with the Company’s legal and ethical obligations. The Coordinators Team has primary and responsibility for implementing this policy, and dealing with any queries about it.

All Company Staff members must comply with this policy.

All Suppliers must comply with this policy.


Group Staff and Suppliers must report any incidence or suspicion of modern slavery at the earliest possible stage to:

(a) If you are a member of Company Staff, your Coordinator; or

(b) If you are a Supplier, your primary account manager or business contact with the Company.


Any Company Staff member who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

The relevant member of the Company may terminate its relationship with a Supplier if it is in breach this policy. Alternatively, the relevant member of the Company may elect to work with the Supplier to resolve such issues.


The Management Team, in conjunction with Purchasing and Human Resources, is responsible for reviewing this policy as necessary to ensure that it meets legal and ethical requirements and reflects best practice. This policy does not form part of any contract of employment and may be amended at anytime.



Alison Smith: Financial Director

Llew de Souza: Managing Director


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