ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Anti-Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery 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 and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.

All commercial organisations with an Annual Turnover of £36 million and above are subject to the Modern Slavery Act 2015 and must report annually on the steps that they have taken during the financial year to ensure that slavery and human trafficking are not taking place in their own business or in their supply chains.

Turnex Ltd Statement

Whilst Turnex Ltd is not subject to the reporting requirements of the Modern Slavery Act 2015, it supports the government’s objectives to eradicate modern slavery and human trafficking.
Turnex Ltd is committed to the highest level of ethical standards and sound governance arrangements, and sets high standards of impartiality, integrity and objectivity in relation to the management of its activities.

Turnex Ltd does not knowingly participate in human trafficking, it does not treat people as slaves and pays the people who work for the organisation a decent living wage. It reserves the right to seek assurances from any organisation with which it trades that the organisation is not participating in any activity that would be in breach of the Modern Slavery Act 2015.

Turnex Ltd expects high standards from all of our subcontractors, suppliers and other business partners and have made this a contractual term in our agreements with significant suppliers wherever possible. This policy applies to all persons working for Turnex Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee's contract of employment and we may amend it at any time.

Supply Chain

Turnex Ltd operates and maintains an Approved Supplier List. We conduct due diligence on all suppliers before allowing them to become an approved supplier. We require that they confirm to us that:

Responsibility for The Policy

The company’s director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our employees comply with it.

Compliance With The Policy

You must ensure that you read, understand and comply with this policy.

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. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Although you should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains in accordance with our whistleblowing policy, you are also encouraged to discuss a specific matter (or our policy or relevant legislation) with the company’s director. If you are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then err on the side of caution and report it in accordance with the whistleblowing policy, or speak to the company’s director.

We encourage openness and will support anyone who raises genuine concerns in good faith in accordance with the company’s whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.

Communication and Awareness of This Policy

Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. Breaches of This Policy Any employee who breaches this policy could 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.

Monitoring Our Procedures

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 will be reviewed and updated annually or wherever a change is required by the company’s director.