Purpose and Scope
The purpose of this Anti-slavery Policy, is to provide rules and guidance on the avoidance of modern slavery, and appropriate actions to take should an employee or the organisation become aware of any of Blaze Networks’ suppliers or subcontractors being suspected of modern slavery.
The scope includes all staff, all subcontractors, and all information assets such as for example high-level infrastructure, servers, firewalls, networking equipment, workstations, and mobile devices, as well as remote access connections used to do work on behalf of Blaze Networks, including reading or sending e-mail and viewing intranet web resources, and any personal computers and/or servers authorised to access Blaze Networks data networks.
Applicable Legislation: Human Rights Act 1998
Abstract
Blaze Networks Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Who does the policy apply to?
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, agents, contractors and suppliers.
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced or compulsory labour, bonded labour, child labour, and human trafficking.
Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Servitude, forced or compulsory labour, or bonded labour happens when worker identity or immigration documents are withheld until a certain amount of work has been done, a certain amount of time has elapsed, or a monetary value has been paid off, with the workers very often finding themselves in an untenable situation with continually moving goal posts, at the whim of the employer.
Child labour is when work is performed by a person under the age of 18 that jeopardises their physical, mental or moral well-being. It includes work that takes place under particularly difficult conditions such as work for long hours or during the night.
Modern slavery is a crime and a violation of fundamental human rights.
Commitments
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- We have a zero-tolerance approach to any and all forms of modern slavery and human trafficking in our organisation and our supply chains.
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
- Our staff must not engage in, or facilitate any activity that might lead to, or suggest, a breach of this policy. Staff are also required to notify management should they become aware of any other member of staff or one of our suppliers being in breach of this policy.
- Training on the prevention of modern slavery will be provided to all staff dealing directly with suppliers, or as otherwise deemed necessary.
- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
- We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
Consistent with our risk-based approach we may require:
- Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
- Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code of Conduct
- As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct
- If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.