NATTC Modern Slavery & Human Trafficking Policy

1. Introduction

1.1. Purpose: NATTC is committed to preventing and combating modern slavery and human trafficking in all its forms, in line with international and domestic legal obligations.

1.2. Scope: This policy applies to all employees, contractors, agents, suppliers, and anyone acting on behalf of NATTC, collectively referred to as “covered persons.”

2. Policy Statement

2.1. NATTC condemns modern slavery and human trafficking in the strongest possible terms and is dedicated to:

a) Ensuring that slavery, servitude, forced labour, and human trafficking are not present in any part of our operations or supply chains.

b) Complying with all applicable laws and regulations related to modern slavery and human trafficking, including the Modern Slavery Act 2015.

c) Collaborating with governmental and non-governmental organizations, as well as business partners, to prevent and address modern slavery and human trafficking.

d) Regularly reviewing and updating our policies and procedures to ensure their effectiveness in combating these issues.

3. Definitions

3.1. Modern Slavery: Modern slavery encompasses slavery, servitude, forced labour, and human trafficking. These terms are defined as follows:

a) Slavery: The condition in which a person is forced to work against their will, often for little or no pay, and is treated as property.

b) Servitude: The obligation to provide services under the menace of penalties and where the person does not enter into the service willingly.

c) Forced Labor: Work or services extracted from a person under threat, coercion, or deception, with no option to refuse or leave.

d) Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, use of force, or other forms of coercion, for the purpose of exploitation.

4. Due Diligence and Risk Assessment

4.1. NATTC will conduct risk assessments to identify and assess the risk of modern slavery and human trafficking in its operations and supply chains.

4.2. We will carry out due diligence processes to:

a) Identify, prevent, and mitigate risks of modern slavery and human trafficking.

b) Screen and assess suppliers and business partners for compliance with this policy.

5. Training and Awareness

5.1. NATTC will provide regular training and awareness programs for employees and relevant stakeholders to recognise and report signs of modern slavery and human trafficking.

6. Reporting Suspected Violations

6.1. Any covered person who becomes aware of or suspects a violation of this policy or any incident of modern slavery or human trafficking must report it promptly to Graham Huggins CEO

6.2. NATTC encourages the reporting of suspected violations without fear of retaliation. Reports can be made anonymously.

7. Consequences of Violations

7.1. Violations of this policy will result in disciplinary action, up to and including termination of employment or contractual relationships and may lead to civil or criminal prosecution.

8. Review and Update

8.1. This policy will be reviewed periodically to ensure its continued effectiveness in combating modern slavery and human trafficking.

9. Conclusion

9.1. NATTC is committed to taking all necessary steps to prevent, detect, and eliminate modern slavery and human trafficking from its operations and supply chains. Our commitment to these principles underscores our dedication to ethical and responsible business practices.

NATTC 10/10/2023

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