This policy is approved by the Bluestones Investment Group Limited Board and is reviewed annually.
The policy applies to Bluestones Investment Group Limited and its subsidiary companies (except subsidiary companies that have published a separate modern slavery-related policy on their website).
References to the Group relate to Bluestones Investment Group Limited and its subsidiary companies. References to ‘we’, ‘us’ ‘our’ etc are intended to relate to each company within the Group to which this policy applies.
This policy applies to all persons working with us or on our behalf in any capacity, including employees at all levels, directors, officers, consultants, agency workers, contractors and suppliers.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
You must ensure that you read, understand, and comply with this policy.
The Managing Director of each company within the Group has overall responsibility for ensuring that their company and those working for or on behalf of their company complies with this policy.
If you suspect a breach you must notify your manager, Board Sponsor or the Bluestones Group Head of Legal as soon as possible. Concerns about any issue or suspicions of modern slavery in our business or supply chains should be raised at the earliest possible stage. Concerns may also be reported in accordance with our Whistleblowing Policy.
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 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 promptly inform the HR Department (HR@bluestonesgroup.co.uk). You may also raise concerns in accordance with our Grievance Policy.
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 are committed to conducting our business dealings and relationships in a way that safeguards against modern slavery 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.
The systems and controls used in relevant business dealings and relationships include due diligence processes, due diligence questionnaires, compliance audits, the use of specific contractual provisions with third parties relating to compliance with this policy and the Modern Slavery Act 2015 and regular monitoring. The appropriate systems and controls will be determined in line with our commitment in this Policy.
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 and on our behalf. Individuals and companies must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
We have a zero-tolerance approach to modern slavery in our organisation and supply chains.
We expect the same high standards from all of our contractors, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards.
We are committed to providing awareness information and training around modern slavery to all individuals who work for us.
Breaches of this Policy
Alleged breaches of this policy will be taken seriously, and we commit to investigating such matters at an appropriate level of seniority in an effective and expeditious manner.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.