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Modern Slavery Policy

 

Introduction

 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “MSA”) on behalf of The Paperback Shop.co.uk Limited, a company registered in England and Wales with registered company number 3929651 and PBShop.co.uk Limited, a company registered in England and Wales with registered company number 9366362 This statement has been approved by the board of directors.

 

The Company has a zero-tolerance approach to modern slavery, and 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.  We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

 

We are committed to acting responsibly and with integrity in all our business relationships and we continue to take measures to implement and enforce effective systems and processes to ensure that modern slavery and human trafficking is not taking place anywhere within our control or influence.

 

This policy applies to all persons working for us 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 business partners.

 

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

 

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our contractors, suppliers and other business partners will hold their own contractors, suppliers and other business partners to the same high standards.

 

Responsibility for the policy

The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

 

The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

 

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

 

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

 

You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

 

You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

 

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.

 

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

 

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

 

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

 

This Modern (Anti) Slavery Policy and Statement is intended for businesses in all countries, especially the United Kingdom.

 

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.

 

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 

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.

 

We operate zero tolerance to slavery and human trafficking within our business. We expect all those in our supply chains to comply with our values. We continue to assess our supply contracts by size and risk profile and continue to, wherever possible and commercially viable, purchase goods and services from established suppliers in the UK.

 

We acknowledge our responsibility to be alert to the risks of modern slavery and human trafficking in our supply chains. We consider the risks in our current supply chains to be low, based on the location of the majority of our suppliers and product/service categories that we purchase.

 

Nevertheless, we continue to monitor and develop our responsibilities in this regard, as appropriate.

 

We are committed to the continuous improvement of our knowledge and efforts in eradicating modern slavery.