Anti Slavery Policy 

Purpose and Commitment

Owen Reed Limited (“Owen Reed” or “the Company”) is steadfast in its commitment to integrity, professionalism, and fairness in all its business operations and relationships. A fundamental element of this commitment is the adherence to Equality and Inclusion principles, underpinned by a strict zero-tolerance stance on slavery and human trafficking. This policy outlines Owen Reed’s approach to preventing acts of slavery and human trafficking in its business operations and its supply chain.

Scope

This policy applies universally to all individuals working for or on behalf of Owen Reed, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners, suppliers, and any other business entity or individual associated with Owen Reed, irrespective of their geographic location.

Legal Framework

Owen Reed is committed to ensuring that it and its suppliers abide by the laws and regulations of the countries they operate in, with particular adherence to the UK laws, including the Equality Act 2010 and the Modern Slavery Act 2015. This commitment extends to our conduct both domestically and internationally, ensuring we uphold the highest standards of equality, diversity, and inclusion.

Supplier and Contractor Compliance

Owen Reed expects all its suppliers and contractors to comply with the Equality Act 2010 and other relevant legislation, and to:

• Promote equality, diversity, and inclusion, actively working to eliminate unlawful discrimination.
• Ensure no unlawful discrimination occurs within their operations due to protected characteristics under the Equality Act 2010.
• Implement fair and transparent procedures for recruitment, remuneration, promotion, and disciplinary actions.
• Take serious measures against accusations of bullying, harassment, and victimisation.
• Reporting and Accountability

Should any individual associated with Owen Reed suspect an incident of slavery or human trafficking within our operations or supply chain, they are urged to report it immediately to Owen Reed’s Procurement team at [contact details], or to the Procurement Operations Manager directly.

Anti-Slavery Measures

Owen Reed and its suppliers are expected to:

• Respect and uphold the human rights for all workers, and to comply with relevant legislation, regulations, and directives.
• Prohibit forced labour, slavery, and human trafficking within their operations and supply chains.
• Ensure wages meet legal minimums and are free from unauthorised deductions.
• Allow employees the freedom to legally organise and join associations.
• Ensure working hours comply with local regulations and industry practices, with voluntary overtime kept at a manageable level.
• Monitoring and Enforcement

Owen Reed will regularly review its supply chains and internal operations to monitor compliance with this Anti-Slavery Policy. Any breach of this policy will result in immediate investigation and appropriate remedial actions, including terminating contracts with suppliers who fail to comply.

Training and Awareness

Owen Reed will provide training and resources to ensure its workforce and suppliers are aware of the issues surrounding slavery and human trafficking, and understand how to identify and report potential exploitation within our supply chain.

Policy Review

This policy will be regularly reviewed and updated as necessary to ensure its effectiveness and compliance with current legislation. Feedback from employees, suppliers, clients, and external organisations will be incorporated to enhance the policy.

Approval and Implementation

This policy has been approved by the senior management of Owen Reed and is effective immediately. It is the responsibility of everyone within the Company to contribute to its successful implementation.

Approved by:

Name: Sebastian Pampanini

Position: Operations Director

Date: 29 February 2024N