Modern Slavery Policy

1. Purpose and scope 
This policy is intended to supplement but not replace any applicable UK government laws, and treaty laws governing UK Limited companies. This policy is intended to supplement but not replace any other policy in place by Broadleaf Global Limited (“Broadleaf”). 

2. Policy Statement 
Here at Broadleaf, we believe in the fundamental rights of all humans, and are wholly opposed to modern slavery in all its forms – human trafficking, slavery, forced labour and domestic servitude. 

Broadleaf has a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We implement and embed appropriate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery, consistent with our disclosure obligations under the Modern Slavery Act 2015. 

We expect the same high standards from all our contractors, suppliers and other business partners. As part of our standard terms of business, we include specific provision for full compliance with this policy for all suppliers and customers of Broadleaf. 

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. 

2.1 Responsibility for the policy 
Broadleaf has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Broadleaf has primary day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and 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 improves. Comments, suggestions and queries are encouraged and should be addressed to Paul Dykes. 

2.2 Compliance with the policy 
Read this policy and confirm you have done so to your line manager or a Broadleaf Director. 

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 line manager OR a Broadleaf Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. 

Raise any concerns you have about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier 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 line manager or Broadleaf Director OR report it in accordance with our Whistleblowing Policy as soon as possible. 

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. 

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any part of our supply chain constitutes any of the various forms of modern slavery, raise it with your line manager or a Broadleaf Director. 

We 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 part of our supply chain. 

If you believe you have suffered detrimental treatment as a result of raising a concern under this policy – disciplinary action, threats or other unfavourable treatment – you should inform your line manager or a Broadleaf Director immediately. If the matter is not resolved and you are an employee, you should raise it formally using our Grievance Policy, which can be found in the Policies area of the ‘People’ folder on our SharePoint site. 

2.3 Communication and awareness of this policy 
Training on this policy, and on the risk our business faces from modern slavery in our supply chain forms part of the induction process for all individuals who work for us. Updates will be provided using established methods of communication between Broadleaf and you. 

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. 

2.4 Breaches of this policy
Any employee of Broadleaf 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. 

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