Anti-Slavery Policy

In the UK, the relevant legislation is the Modern Slavery Act 2015 (“the Act”). The Act received Royal Assent on 26th March 2016 and created a framework to: 

• consolidate and simplify existing offences into a single act; 
• ensure that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences); 
• enhance the court’s ability to put restrictions on individuals where it is necessary to protect people from the harm caused by modern slavery offences; 
• create an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery; 
• introduce a defence for victims of slavery and trafficking; 

• place a duty on the secretary of state to produce statutory guidance on victim identification and victim services; 
• enable the secretary of state to make regulations relating to the identification of and support for victims; 
• make provision for independent child trafficking advocates; 
• introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators; 
• enable law enforcement to stop boats where slaves are suspected of being held or trafficked; 

• require businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains. 

The Act covers: 

• slavery, servitude and forced or compulsory labour; 
• human trafficking; 
• the meaning of exploitation; 

• committing an offence with the intent to commit an offence under section 2. 

Full details of the Act can be found at: Modern Slavery Act 2015 

Additional legislation may apply outside the UK. 

All Incremental’s employees and relevant third parties (i.e. contractors, agents, partners, suppliers or any other person/group acting on Incremental’s behalf) must comply with this policy. 

The policy applies both in the UK and worldwide. Where local laws require additional controls, supplementary policies and guidance may be implemented but the requirements of the Act must always be followed. 

At Incremental, we conduct all business with integrity. We do not participate in modern slavery or human trafficking in any form. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation. We expect that our customers, contractors, agents, partners suppliers or any other person/group acting on Incremental’s behalf will adhere to the same high standards. 

In our business dealings, we prohibit: 

slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking 

and/or 

the facilitation of travel of another person with a view to that person being exploited 

by any employee, contractor, agent, partner, supplier or any other person/group acting on Incremental’s behalf 

in order to gain any commercial or personal advantage (financial or otherwise) 

Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual/organisation concerned and may cause serious damage to the reputation and standing of Incremental. If the breach involves an Incremental employee, they are likely to face disciplinary action, criminal proceedings and dismissal. In the case of third parties, the relevant contract will be terminated. 

Any concerns relating to a breach of the policy should be reported in one of the following ways: 

• your Line Manager; 
• the People Director; 
• the Chief Financial Officer; 

• the Chief Executive Officer. 

Employees raising concerns are protected by Incremental’s Whistleblowing Policy. 

We will conduct risk assessments across the business on a regular basis with the aim of: 

• identifying any employees or officers of Incremental who are in positions where they may be exposed to modern slavery or human trafficking, in order that relevant training can be provided. This training will be mandatory; 
• identifying any aspects of our business where modern slavery or human trafficking is a risk in order that proportionate procedures can be implemented where necessary. 

General guidance will be cascaded through senior management and line managers and will be made available to all employees. 

This policy will be communicated to relevant third parties in order that they are aware of their obligations. Incremental will conduct an effective and appropriate process of diligence prior to entering significant business relationships and will keep a record of this process. 

Line Managers are responsible for monitoring compliance with this Policy and reporting the results to Incremental’s Operational Board. On an annual basis, Incremental’s Operational Board will review the implementation of this Policy in respect of its suitability, adequacy and effectiveness and make improvements as appropriate. 

Incremental expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery: 

• a zero-tolerance approach to modern slavery in our organisation and our third-party operations; 

• the prevention, detection and reporting of modern slavery in any part of our organisation or third-party operations is the responsibility of all those working for us or on our behalf. Employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy; 
• committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations; 
• a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. 

Consistent with our risk-based approach we may require: 

• employment and recruitment agencies and other third parties supplying employees/contractors to our organisation to confirm their compliance with our Code of Conduct; 

• suppliers engaging employees/contractors through a third party to obtain that third parties’ agreement to adhere to the Code; 
• as part of our ongoing risk assessment and due diligence processes to consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct; 
• if we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships. 

Further relevant information and guidance about the Act can be found here.