Modern Slavery Statement

Modern Slavery Policy

This statement has been prepared pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). It sets out the new and ongoing steps we are taking to address and prevent modern slavery taking place, both within our business and our supply chains.

  1. Harcourt Patterson Group Limited (“HPG”) is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
  2. HPG is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
  3. HPG provides appropriate training and awareness information for all of its staff. In particular:
    1. Our Directors receive training in identifying and resolving concerns around modern slavery and human trafficking.
    2. All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
  4. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to a Director.
  5. The cost of recruitment is a business cost and no fee or cost for recruitment will be charged to workers, directly or indirectly, in whole or in part.
  6. Reports surrounding these issues are taken extremely seriously by Directors who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
    1. Working with the appropriate organisations to improve standards,
    2. Removing that organisation from our preferred supplier list,
    3. Passing details to appropriate law enforcement bodies.
  7. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
    1. The level of modern slavery training and awareness amongst our staff.

This policy was adopted on 15 March 2021 after being agreed by Directors. It is reviewed annually. It was last updated 13 March 2022.