Narwhal Group Limited
Modern Slavery and Human Trafficking Policy
1. Introduction
Narwhal Group Limited (“the Company”) is committed to conducting business with honesty, integrity, and respect for human rights. We take a zero-tolerance approach to any form of modern slavery, human trafficking, forced labour, or other abuse of human rights in our operations or supply chains. This policy outlines our commitment to preventing and addressing modern slavery risks and ensuring compliance with all applicable legislation, including the UK Modern Slavery Act 2015 (where relevant).
2. Scope and Purpose
This policy applies to all individuals working for or on behalf of Narwhal Group Limited, including employees at all levels, directors, officers, agency workers, volunteers, agents, contractors, external consultants, third-party representatives, and business partners. We expect all who engage with us to share our commitment to preventing modern slavery and human trafficking.
3. Our Commitment
- Compliance With Laws
- We comply with all relevant legislation and regulations in the jurisdictions in which we operate, including laws against forced labour, child labour, and human trafficking.
- Risk Assessment and Due Diligence
- We will conduct periodic risk assessments of our operations and supply chains to identify potential areas of vulnerability.
- We will evaluate new and existing suppliers, contractors, and business partners based on their adherence to legal and ethical labour standards, including modern slavery prevention.
- Supplier and Partner Expectations
- We expect our suppliers, contractors, and business partners to uphold ethical standards and comply with our zero-tolerance approach to modern slavery.
- We may terminate business relationships with any partner that fails to meet our anti-slavery and human rights expectations.
- Training and Awareness
- We will provide relevant training to employees and key decision-makers so they can recognize and address risks related to modern slavery and human trafficking.
- We will communicate our policy to all staff and make it publicly available to stakeholders.
- Reporting Mechanisms
- We encourage anyone with concerns about potential modern slavery in our business or supply chain to report such concerns immediately.
- Reports can be made confidentially to the Human Resources department or through the Company’s whistleblowing channel.
- Remedial Action
- If modern slavery or human trafficking is identified in our operations or supply chain, we will take prompt action to address it, cooperating with relevant authorities as necessary.
- Monitoring and Continuous Improvement
- We will review the effectiveness of our policy and procedures annually to ensure they remain fit for purpose and reflect the latest legal requirements and best practices.
4. Roles and Responsibilities
- Board of Directors: Overall responsibility for ensuring the Company upholds this policy and meets its legal and ethical obligations.
- Management: Responsible for implementing and maintaining procedures that support the policy and for carrying out appropriate due diligence when engaging suppliers or business partners.
- Employees: Required to follow this policy, report any concerns related to modern slavery and human trafficking, and complete relevant training.
5. Communication and Review
This policy is made available to all employees and is published on our website (where applicable) to ensure transparency. It will be reviewed annually by the Board of Directors, who will ensure that it remains in line with any changes to legislation, evolving best practices, and the Company’s operational needs.