Anti-slavery and Human Trafficking Policy
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. We have a zerotolerance 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 taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure 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.
1.3 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.
1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
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, and that all those under our control comply with it.
2.2 The Factory Manager 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.
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 You 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 manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
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. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify Factory Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must Factory Manager report it in accordance with our Whistleblowing Policy as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
3.6 If you 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, raise it with your Factory Manager.
3.7 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. We are committed to ensuring no one 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 you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Company Handbook.
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 individuals who work for us, and regular training will be provided as necessary.
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.
STATEMENT ON OUR ETHICAL TRADING CODE OF CONDUCT & EMPLOYMENT RIGHTS
We are committed towards ethical trading and employment practices within WI International Limited. We are committed to ensuring good standards within our business in so far as employment of our colleagues in the company and also among its suppliers and engaging with the supply base to bring about improvement. WI International Limited will only work with reputable suppliers and manufacturers who are committed to working towards compliance with the conditions set out in this code. A process of self-evaluation, independent audit and training is in place to ensure that continuous improvement is made.
Hours of Work
Our aim is to ensure working hours comply with national laws and benchmark industry standards, which ever affords greater protection.
In any event, employees shall not on a regular basis be required to work in excess of 48 hours per week over any 17-week reference period (European Working Hours Directive) and shall be provided with at least one day off for every 7-day period on average.
Due to the fluctuating demand for our products on occasions there is a business need to run additional production hours. Outside of the need to roster staff to meet production demand overtime is voluntary. In any event the working hours shall not exceed 12 hours per day, it shall not be demanded on a regular basis and shall always be compensated at a premium rate.
Wages / Pay
Our wages and benefits paid for a standard working week meet, at a minimum, national legal standards, or industry benchmark standards, whichever is higher. In any event our wages are always above the minimum wage.
We pay for all hours during working time.
We do make any deductions from pay unless authorised to do so. We do not deduct pay as a disciplinary measure and we do not deduct pay not provided for by national law without the expressed permission of the employee concerned. All disciplinary measures are recorded.
Ethical Trading Policy (last reviewed June 2016)
Our Ethical Trading Policy is communicated to our employees via the Employee Noticeboard and to our suppliers in our dealings with them. Through our normal day to day business with customers we communicate this policy.
Employee Handbook
The Employee handbook is issued to all employees on joining the company and is signed for as an acknowledgment that the handbook has been issued. It is also issued to existing staff when the handbook is updated each time.
The handbook is available in paper and electronic format. (For a copy of this Handbook please request one from HR).
Freedom of Association
Freedom Of Association and The Right To Collective Bargaining Are respected
Employees, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
WI International Ltd adopts an open attitude towards the activities of trade unions and their organisational activities. Employee representatives are not discriminated against and have access to carry out their representative functions in the workplace.
Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
Grievance Procedure
Our Grievance procedure is laid out in detail in the Company’s Handbook. We aim to resolve all grievances where possible to the employee’s satisfaction provided there are reasonable grounds for doing so.
Staff Consultative Committee (Works Council)
Our policy regarding the Company’s staff consultative committee is to support and facilitate Staff Consultation within WI International Ltd.
Employment Contracts
All employees are issued with and have an ongoing current contract of employment in accordance with Section 1 of the Employment Rights Act 1996. This statement provides details of the principal terms and conditions of employment with the Company. The documents are issued to all new employees within the first 8 weeks of employment. Variation to terms are issued to all employees during the course of their employment.
Our aim is to ensure that all employees are issued with fair and consistent terms of employment which are signed by a company representative and employee. The signed terms of employment are held by the employee and a copy is held on the personal file held in the company’s HR department
Child Labour and Young Workers Register
WI International Ltd policy is that there shall be no new recruitment / employment of child labour.
The WI International Ltd shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; children and young persons under 18 shall not be employed at night or in hazardous conditions.
The policies and procedures relating to the employment of children shall conform to the provisions of the relevant ILO standards.
As a result there are no records of child labour held within WI International Ltd. Definitions:
Child – Any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply.
Young person – Any worker over the age of a child as defined above and under the age of 18. Child Labour: Any work by a child or young person younger than the age(s) specified in the above definitions which does not comply with the previsions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child’s or young person’s education, or to be harmful to the child’s or young person’s health or physical, mental, spiritual, moral or social development.
