GEV Wind Power Anti-Slavery Policy
1.1 GEV Holdings Ltd and all subsidiaries (“the Company”) is committed to ensuring there is transparency in its business and the approach to tackle modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all its suppliers, contractors and other third parties. As part of the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in this policy.
1.2 The policy sets out the Company’s zero tolerance approach to modern slavery. The Company is committed to acting ethically and with integrity in all its business dealings and relationships; implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the business operations or any of the Company’s supply chains.
1.3 Modern slavery is a crime and a violation of fundamental human rights. The Company recognises this comes in various forms such as: slavery, servitude, forced and compulsory labour and human trafficking. All have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
1.4 The HR team and board of directors have overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and all staff and third parties under its control, comply with it.
1.5 This policy does not form part of the employee’s contract of employment and the Company may amend it at any time.
2.1 The Company aims 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. The Company is 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 the business or in any of the Company’s supply chains. Detrimental treatment includes disciplinary action, dismissal, threats or other unfavourable treatment connected with raising a concern. If any staff member believes they have been subject to such treatment, the individual must inform their manager or the HR team immediately. If the matter is not resolved, the employee can raise this formally, following the Company’s Grievance Procedure.
3. Who does the policy apply to?
3.1 The policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors and officers (“Staff”), and third parties including agency workers, customers, suppliers seconded workers, volunteers, interns, agents, contractors, external consultants (“third parties”).
4. Compliance with the policy
4.1 All staff and third parties must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.2 All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains of any supplier tier at the earliest possible stage.
4.3 If any staff believe or suspect a breach of this policy has occurred or that it may occur the individual must notify either their manager or the HR team as soon as possible. Third parties should notify a senior member of staff.
4.4 If staff or third parties are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various forms of modern slavery, this should be raised as set out in paragraph 4.3.
4.5 All managers are responsible for ensuring that this policy and the Company’s zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with this policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.
4.6 All members of the management team have 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.
4.7 All managers must ensure that this policy and the Company’s zero-tolerance approach to modern slavery is communicated to all third parties at the outset of each business relationship.
4.8 Managers are responsible for ensuring that all relevant existing third-party contracts include obligations to comply with the Modern Slavery Act and new third-party contracts contain applicable prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 The Company may terminate its relationship with other third parties if they breach this policy.