Anti-Slavery and Human Trafficking Policy
1. Purpose
Pragmatist Consulting is committed to preventing slavery, servitude, forced labor, and human trafficking in all aspects of our operations and supply chains. This policy outlines our stance on modern slavery and the steps we take to ensure compliance with relevant legislation, including the Modern Slavery Act 2015.
2. Scope
This policy applies to all employees, contractors, suppliers, and other business partners working with or on behalf of Pragmatist Consulting.
3. Definitions
Modern Slavery: The recruitment, movement, harbouring, or receiving of children, women, or men through the use of force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation.
Human Trafficking: The act of recruiting, transporting, transferring, harbouring, or receiving people through coercion, abduction, fraud, or deception for the purpose of exploitation.
4. Our Commitment
Zero Tolerance: Pragmatist Consulting has a zero-tolerance approach to modern slavery and human trafficking in any form.
Ethical Standards: We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.
5. Responsibilities
Management: The CEO is responsible for ensuring compliance with this policy and for establishing appropriate systems and controls.
Employees: All employees are required to report any concerns regarding modern slavery or human trafficking in line with our whistleblowing policy.
Suppliers and Partners: Our suppliers and business partners must adhere to the same high standards and demonstrate their commitment to preventing modern slavery.
6. Due Diligence
Pragmatist Consulting conducts due diligence on all new suppliers and reviews existing suppliers to assess the risk of modern slavery and human trafficking. This process includes:
Risk Assessment: Evaluating potential risk areas in our supply chains.
Supplier Audits: Conducting supplier audits where appropriate to ensure adherence to our anti-slavery policy.
Contractual Obligations: Requiring suppliers to agree to our anti-slavery policy or have their own equivalent policy in place.
7. Training and Awareness
We provide training to all employees on modern slavery and human trafficking, ensuring they understand the signs of these issues and know how to report any concerns. This training is part of our induction process and is regularly updated.
8. Reporting and Whistleblowing
Employees, suppliers, and other stakeholders are encouraged to report any concerns related to modern slavery in any parts of our business or supply chains. Reports can be made confidentially through our whistleblowing channels without fear of retaliation.
9. Monitoring and Review
This policy will be reviewed annually by the Compliance department to ensure its effectiveness and compliance with current legislation. Any necessary amendments will be made and communicated to all employees and stakeholders.
10. Consequences of Non-Compliance
Any employee found to be in breach of this policy may face disciplinary action, up to and including termination of employment. Similarly, any supplier found to be in violation of this policy may have their contract terminated.
11. Policy Approval
This policy is approved by Pragmatist Consulting’s CEO and will be reviewed annually.
12. Acknowledgment
By signing below, I acknowledge that I have read, understood, and agree to adhere to Pragmatist Consulting’s Anti-Slavery and Human Trafficking Policy.
Name: Roland Cook
Position: Founder and CEO
Date: 2 August 2024