About this 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 to exploit them for personal or commercial gain.

We are committed to ensuring there is transparency in our own business and in our approach to tackling 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.

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.

This policy does not form part of any employee's contract of employment, and we may amend it at any time. 

Responsibility for the Policy

The Chief of Staff has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Chief Operations Officer 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.

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.

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 Chief Operations Officer.

Compliance with the Policy

You must ensure that you read, understand and comply with 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 or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

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.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

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 manager or the Chief Operations Officer as soon as possible.

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 Chief Operations Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure. 

Communications and awareness of this policy

We expect you to familiarise yourself with this policy and if you are at all unsure of the meaning of any part (or how to implement it) please discuss the matter with your manager. 

If you notice anything that causes you to suspect that the Company or any other organisation we deal with is operating in breach of this policy, it is vital that you raise this immediately with the Chief Operations Officer.

Breaches of this Policy

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.

Responsibilities

All employees are responsible for maintaining awareness of Cambridge Management Consulting’s policies and procedures applicable to their role and for complying with them. All employees are responsible for reporting any concerns, opportunities for improvement, weaknesses, and incidents to security@cambridgemc.com in the first instance and subsequently to their department manager. Incidents must be reported by the fastest possible means.

Compliance

Any breaches of Cambridge Management Consulting’s policies may be subject to a formal security investigation. Where proven, failure to comply will result in disciplinary action being taken against individuals determined to be responsible for the breach under Cambridge Management Consulting’s Disciplinary Process up to and including summary dismissal for gross misconduct. Connect may also initiate legal action or refer the breach to relevant law enforcement authorities where warranted. Noncompliance by contracted third parties or their employees may result in termination of the supplier’s contract. 

Audit

Audit spot checks and automated monitoring may be conducted to ensure this policy is complied with. Any noncompliance will be reported to security@cambridgemc.com in the first instance to initiate investigation of any associated incident.