Modern Slavery Policy
Modern slavery is the illegal exploitation of people for personal or commercial gain. Victims are controlled by force, threat, coercion and/or deception.
Everwell Associates Limited has a zero tolerance approach to modern slavery and human trafficking in all aspects of our business operations. We expect all associates, employees, contractors, suppliers, and business partners to adhere to the highest ethical standards and to comply with all applicable laws and regulations related to slavery and human trafficking.
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 Board are responsible for endorsing our modern slavery strategy, of which this policy is part.
All Associates are responsible for ensuring those reporting to them are aware of and understand this policy.
Our commitments
Everwell associates Limited complies with all applicable legislation, including the Modern Slavery Act 2015 (which includes the publication of an annual anti-slavery and human trafficking statement) and the Human Rights Act 1998.
We respect the human rights of all our employees and provide them with a safe working environment and fair terms of employment.
Third parties
We expect high standards from all our associates, contractors, suppliers and other business partners. We expect them to comply with all applicable laws and regulations and publish an annual anti-slavery and human trafficking statement, where they are legally required to do so.
Consideration of modern slavery risk is built into our procurement processes as part of our due diligence activities.
Our procurement contracts require suppliers to comply with the Modern Slavery Act 2015, in addition to other relevant policies. We also include specific requirements that our suppliers implement due diligence procedures for their own supply chains and use reasonable endeavours not to purchase resources or products from organisations using forced labour.
We expect our suppliers to hold their own suppliers to these same high standards.
We will terminate our relationship with individuals and organisations working on our behalf if they are found to be in breach of the Modern Slavery Act.
Training and Awareness
We will provide training and raise awareness among our employees about the risks of slavery and human trafficking and how to identify and report any potential issues.
The warning signs to look out for:
• workers who don’t have written contracts of employment
• workers who have had to pay fees to obtain work
• workers who are not able to prove they are legally entitled to work in the UK
• workers showing signs of physical abuse and/or appear malnourished or unkempt
• workers who seem to have few personal possessions or often wear the same clothes
• workers who appear frightened or reluctant to talk to others
• workers who are dropped off or collected for work by the same person regularly, possibly very early or very late at night
• a large number of people listed as living at the same address
• multiple people being paid into the same bank account
• multiple people providing the same next of kin details
• agencies charging suspiciously low rates against standard industry pricing.
Reporting and Investigation
We encourage all employees, contractors, and suppliers to report any concerns or suspicions of slavery or human trafficking to our designated compliance officer. We will investigate all reports thoroughly and take appropriate action if needed.
Monitoring and Review
We will regularly monitor and review our policies and procedures to ensure that they are effective in preventing slavery and human trafficking in our business operations.
Communication
We will communicate our slavery and human trafficking policy to all employees, contractors, suppliers, and business partners and make it available to the public on our website.
By implementing this policy, Everwell Associates Limited aims to create a safe and ethical working environment for all individuals involved in our business operations and to contribute to the eradication of slavery and human trafficking worldwide.
Anti Slavery Policy Review: September 2027