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Modern Slavery and Human Trafficking Policy

1. Purpose

Cleyro Ltd is committed to maintaining high ethical standards in every aspect of our business operations. This policy outlines our stance on modern slavery, human trafficking, and exploitation. We aim to ensure that modern slavery does not exist within our supply chain or any of our business operations.

 

2. Scope 

This policy applies to all employees, contractors, suppliers, and other partners associated with Cleyro Ltd, both in the UK and internationally. It covers the prevention, detection, and response to any form of modern slavery or human trafficking.

 

3. Definition of Modern Slavery

Modern slavery refers to the exploitation of individuals through coercion, threats, or deception. This includes:

 

- Slavery  

- Human trafficking  

- Forced or compulsory labour  

- Child labour  

- Debt bondage  

- Servitude

 

4. Commitment to Anti-Slavery Practices

Cleyro Ltd is committed to acting ethically and with integrity in all our business dealings and relationships. We will not tolerate any form of slavery or human trafficking in our operations, supply chain, or within our network of contractors and suppliers. We aim to:

 

- Ensure transparency and accountability in all business activities  

- Implement and enforce effective systems and controls to identify and mitigate risks  

- Protect the rights and well-being of workers, ensuring that they are treated fairly and respectfully  

- Promote fair recruitment practices and ensure that no worker is coerced into employment  

 

5. Supply Chain Due Diligence

Cleyro Ltd conducts thorough due diligence when selecting suppliers, contractors, and business partners. We require our suppliers and partners to comply with the following principles:

 

- Prohibit modern slavery and human trafficking within their operations  

- Ensure fair wages and safe working conditions for all employees  

- Provide clear and transparent contracts to workers  

- Avoid child or forced labour in all stages of the supply chain  

 

We also reserve the right to conduct audits of our suppliers’ and partners’ operations to ensure they meet these standards. Any supplier found to be engaging in practices related to modern slavery will face immediate investigation and potential termination of the business relationship.

 

6. Recruitment and Employment

Cleyro Ltd adheres to fair and transparent recruitment practices. We:

 

- Ensure that all employees are employed voluntarily and have the right to work  

- Maintain proper documentation for all employees, including contracts of employment  

- Do not withhold any employee’s identity or personal documents as a form of control  

- Provide our employees with adequate training on their rights and responsibilities  

 

7. Training and Awareness

We are committed to raising awareness of modern slavery and human trafficking within our workforce. Cleyro Ltd will:

 

- Provide training on the risks of modern slavery to all employees and key stakeholders  

- Educate staff on how to identify potential signs of modern slavery  

- Encourage employees to report any concerns or suspicions regarding modern slavery practices without fear of retaliation  

 

8. Reporting and Whistleblowing

Cleyro Ltd encourages employees, suppliers, and other stakeholders to report any concerns regarding modern slavery. Reports can be made through a designated point of contact within the company.

 

We will investigate any reports of modern slavery and take appropriate action to address the issue. Retaliation against any individual reporting concerns in good faith will not be tolerated.

 

9. Monitoring and Auditing

Cleyro Ltd regularly monitors its business operations and supply chains to ensure compliance with this policy. Our efforts include:

 

- Auditing suppliers and subcontractors to verify compliance with anti-slavery standards  

- Reviewing and updating internal practices, policies, and controls to better mitigate risks  

- Reporting on the effectiveness of our anti-slavery efforts  

 

10. Enforcement and Consequences

Any breach of this policy by employees or partners will result in disciplinary action, including potential termination of employment or business relationships. If a supplier is found to have engaged in modern slavery practices, we may immediately terminate the contract and seek legal recourse where applicable.

 

11. Review and Revision

Cleyro Ltd reviews this policy regularly to ensure its effectiveness in preventing modern slavery. The policy may be revised as necessary in response to new legal requirements, emerging risks, or lessons learned from audits and investigations.

 

12. Policy Approval

This policy has been approved by Cleyro Ltd’s Board of Directors. It is reviewed annually to ensure its relevance and effectiveness.

 

Contact Information

For any questions or concerns regarding this policy, please contact:  

Cleyro Ltd

Email: info@cleyro.com

Phone: 01173 253 976

This document is designed to ensure that Cleyro Ltd takes an active and transparent stance against modern slavery and is aligned with ethical business practices. The company is dedicated to continuing its efforts in safeguarding human rights throughout its operations.

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