QSE-Doc. No.
Anti-Slavery and Human Trafficking Policy Created
Riegler, Markus, 20.06.2024
Amended
Riegler, Markus, 20.06.2024
Checked
Mistry, Nautam, 17.07.2024
DB-LPZ-46
Version No.
1
Approved
Bowen, Fergus, 17.07.2024
(1) Scope of application This document applies to Bene PLC.
(2) POLICY STATEMENT 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 have a zerotolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships 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. Our Purchasing Policy also provides information on what we expect from our suppliers, contractors and partners. We also require their own suppliers to adhere to this policy in their procurement chains. Together with the guidelines outlined herein and in our Purchasing Policy we set out our expectations and obligations as a business and expect all suppliers, contractors and partners to adhere to Bene’s commitment to anti-slavery and human trafficking. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern 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, contractors and 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. All suppliers, contractors and partners should also note our commitments to, amongst other things, working conditions; freedom of work; child labour; anti-discrimination; fair treatment; wages, social payments and working rules as set out in our Purchasing Policy. We will exercise reasonable diligence at all times to ensure that our supply chains and those of our suppliers, contractors and partners are free from slavery and human trafficking practices. 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.
(3) RESPONSIBILITY FOR THE POLICY The board of directors 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 Managing Director 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.
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