Anti Slavery Policy

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Anti-Slavery and Human Trafficking Policy

GML Security

1. Introduction

GML Security is committed to acting ethically and with integrity in all our business dealings and relationships. We have a zero-tolerance approach to modern slavery and human trafficking, which are crimes and a violation of fundamental human rights. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy applies to all individuals working for GML Security or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and suppliers.

2. Purpose

This policy sets out GML Security’s approach to preventing modern slavery and human trafficking. It aims to:

• Define modern slavery and human trafficking.
• Outline our responsibilities in preventing modern slavery and human trafficking.
• Provide a framework for identifying and assessing the risk of modern slavery and human trafficking in our business and supply chains.
• Establish procedures for reporting concerns.
• Ensure compliance with the Modern Slavery Act 2015 and other relevant legislation.

3. Definition of Modern Slavery

Modern slavery is an umbrella term encompassing slavery, servitude, forced or compulsory labour, and human trafficking. Victims of modern slavery are deprived of their liberty by others for exploitation. It can take various forms, including:

• Slavery: Ownership over a person.
• Servitude: Obligation to provide service imposed by coercion.
• Forced or compulsory labour: Work or service exacted under the menace of a penalty.
• Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation.

4. Our Responsibilities

GML Security will:

• Take a zero-tolerance approach to modern slavery and human trafficking.
• Be committed to acting ethically and with integrity in all our business dealings and relationships.
• Implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
• Ensure compliance with the Modern Slavery Act 2015 and other relevant legislation.
• Provide training to relevant staff to ensure understanding of the risks of modern slavery and human trafficking.
• Encourage the reporting of any concerns or suspicions of modern slavery.
• Thoroughly investigate any reported concerns of modern slavery and take appropriate action.
• Work with our suppliers to ensure they adhere to the same high standards.
• Regularly review and improve our policies and procedures.

5. Risk Assessment

GML Security will:

• Identify and assess potential risk areas in our business and supply chains.
• Evaluate the nature and extent of our exposure to the risk of modern slavery and human trafficking occurring in our business and supply chains.
• Take steps to mitigate those risks.
• Regularly monitor and review the effectiveness of the measures taken.

6. Due Diligence

GML Security will:

• Conduct due diligence on all new suppliers and contractors to assess the risk of modern slavery and human trafficking.
• Incorporate anti-slavery and human trafficking clauses into our contracts with suppliers and contractors.
• Ensure that suppliers and contractors adhere to the Modern Slavery Act 2015 and other relevant legislation.
• Monitor supplier compliance with our anti-slavery and human trafficking policy.

7. Reporting Concerns

GML Security encourages all individuals working for the company or on our behalf to report any concerns or suspicions of modern slavery or human trafficking. Concerns can be raised to [Position/Person Responsible, e.g., HR Manager, Compliance Officer] in person, by phone at [Phone Number], or by email at [Email Address].

GML Security will ensure that all reports are investigated promptly and thoroughly and that the person making the report is protected from any form of retaliation.

8. Training

GML Security will provide training to relevant staff to ensure they:

• Understand the Modern Slavery Act 2015 and other relevant legislation.
• Are aware of the risks of modern slavery and human trafficking in our business and supply chains.
• Can identify potential signs of modern slavery and human trafficking.
• Know how to report concerns.

9. Review of this Policy

This policy will be reviewed regularly to ensure it remains effective and compliant with relevant legislation.

10. Communication

This policy will be communicated to all individuals working for GML Security or on our behalf. It will also be made available to our suppliers and the public.