Anti-Slavery & Human Trafficking Policy

Purpose

FWB is committed to conducting business ethically and with integrity. This policy outlines our commitment to preventing slavery and human trafficking in our business operations and supply chains, in compliance with the Modern Slavery Act 2015.

Scope

This policy applies to all employees, contractors, suppliers, and other business partners of FWB.

Policy Statement

FWB has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Definitions

Modern Slavery: Encompasses slavery, servitude, forced and compulsory labour, and human trafficking.

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

Responsibilities

Board of Directors: Ultimate responsibility for ensuring compliance with this policy.

Managers: Ensure that their teams understand and comply with this policy.

Employees: Report any concerns about modern slavery in any parts of our business or supply chains.

Due Diligence

FWB undertakes due diligence when considering new suppliers and regularly reviews its existing suppliers. Our due diligence and reviews include:

• Evaluating the risk of modern slavery and human trafficking.
• Conducting supplier audits or assessments.
• Requiring suppliers to confirm they comply with this policy.

Risk Assessment and Management

We have identified the following risk areas in our operations and supply chain:

• Zero-hour contracts on supply chain
• Pay below national living wage on supply chain

To mitigate these risks, we:

• Conduct regular training for employees.
• Implement rigorous recruitment practices.
• Establish and maintain strong supplier relationships.

Training and Awareness

FWB provides training to all employees to ensure they understand the risks of modern slavery and human trafficking and can recognise the signs. Training includes:

• Understanding the Modern Slavery Act 2015.
• Identifying signs of modern slavery and human trafficking.
• Procedures for reporting concerns.

Reporting Concerns

Employees, suppliers, and business partners are encouraged to report any concerns about modern slavery and human trafficking. Reports can be made confidentially to:

• Jamie Brown
• Jamie@fwbltd.com

Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Appendix: Modern Slavery Act 2015 Overview

The Modern Slavery Act 2015 is a key legislative measure in the UK that aims to combat slavery and human trafficking. Key provisions include:

• Offenses of slavery, servitude, and forced or compulsory labour.
• Offence of human trafficking.

Last reviewed: 4th January 2025.

This policy is subject to an annual review to ensure it remains current, effective, and compliant with relevant legislation, regulations, and organisational practices. The next scheduled review will take place in January 2026, or earlier if significant changes occur that warrant an update.