Anti-slavery and Human Trafficking
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 to exploit them for personal or commercial gain.
We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We’re committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.
All new suppliers undergo an audit before final onboarding. 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.
This policy applies globally to all Leader Online companies, brands, and 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.
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Responsibility for the policy
The Managing Director in the company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Managing Director in the company has primary and 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.
Line managers 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.
Communication and awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, is a mandatory part of the induction programme for all new employees. This training, alongside other critical policies (such as Health & Safety), is included in the wider HR training via internal HR software. Regular refresher training is provided as necessary.
Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Reporting Concerns (Whistleblowing)
Leader Online encourages all employees and individuals working on our behalf to report any concerns related to modern slavery or human trafficking in our business or supply chains at the earliest possible stage.
If an employee believes or suspects a breach of this policy has occurred, or that it may occur, they are advised to notify their manager or report in accordance with our Whistleblowing Policy as soon as possible.
We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery in any form is taking place or may be taking place within our business or supply chains.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
This policy was written and endorsed by:
Signed: M Leader
Position: CEO
Dated: 1st May 2024
This policy is reviewed annually and was last updated on 1st May 2024.
