The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom. It is designed to tackle slavery in the UK. It is the first of its kind in Europe, and one of the first in the world, to specifically address slavery and human trafficking in the 21st century. The Act consolidates previous offences relating to trafficking and slavery and extends to England and Wales. It became law on 26 March 2015.
The new legislation significantly enhances support and protection for victims, gives law enforcement the tools they need to target today’s slave drivers, ensures perpetrators can be severely punished, and includes a world leading provision to encourage business to take action to ensure their end-to-end supply chains are slavery free.
NTT Europe Limited (the “Company”) is committed to the abolition of slavery and human trafficking and this Policy together with the Company’s Slavery and Human Trafficking Statement published on its website demonstrate the Company’s commitment to eradicate such slavery and human trafficking.
1. Policy statement
1.1. 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.
1.2. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not happening anywhere in our own business or in any of our supply chains. This is consistent with our Core Values.
1.3. We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.4. All new suppliers will be obliged to complete a New Supplier Questionnaire and must be able to demonstrate their compliance with the Modern Slavery Act 2015.
1.5. The Company will provide a Slavery and Human Trafficking Statement on its external website in a clearly accessible position in accordance with the Act.
1.6. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.7. This policy may be amended at any time. Current versions will always be available on the Company’s intranet.
2. Responsibility for the policy
2.1. The Board of Directors has overall responsibility for ensuring this Policy complies with our legal and ethical obligations.
2.2. The Compliance Committee Manager has primary and day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, and dealing with any queries about it.
2.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4. All staff are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Compliance Committee Manager.
3. Compliance with the policy
3.1. All staff must familiarise themselves with this Policy and comply with it
3.2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Staff are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
3.3. Anyone who believes or suspects that a breach of or conflict with this Policy has occurred, or may occur in the future must notify their manager or use the confidential Whistleblowing helpline (see intranet for further details) as soon as possible.
3.4. If staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with their manager or use the confidential Whistleblowing helpline.
3.5. We aim 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 that no individual 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 our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If anyone believes that they have suffered any such treatment, they should inform their line manager, or HR Manager or the COO immediately. If the matter is not remedied, it can be raised formally using the Company’s grievance procedure, which can be found in the NTTE Grievance Policy on the intranet.
4. Communication and awareness of this policy
4.1. 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 new employees, and ongoing training will be provided to existing employees annually.
4.2. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. Breaches of this policy
5.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.