EGO RESTAURANTS HOLDINGS
Modern Slavery and Human Trafficking policy
1. OUR APPROACH
1.1 EGO RESTAURANTS HOLDINGS has a zero-tolerance approach to any form of mistreatment of people and is committed to operate and conduct its business in such a way that human rights are respected and protected. EGO RESTAURANTS HOLDINGS will not permit or condone any form of slavery, servitude forced or compulsory labour or human trafficking. This is known, collectively, as “modern slavery” and more details of this are set out in this policy.
1.2 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, as far as we are able, that modern slavery is not taking place anywhere in our own businesses or in any of our suppliers.
1.3 Modern slavery is a criminal offence under the Modern Slavery Act 2015 and a violation of fundamental human rights. Modern Slavery can take various forms, (which include those summarised in paragraph 1.4 below), 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.
1.4 Modern Slavery includes:
· Slavery: The key element being the deprivation of freedom and behaviour on the part of the offender as it they own the victim.
· Servitude: Forcing an individual to provide services through the use of coercion (including obliging the victim to live on another person’s property and being unable to change this condition).
· Forced/Compulsory Labour: Work or services are obtained from an individual under the menace of any penalty, (such that the individual concerned has not voluntarily offered to provide this work or service).
· Human Trafficking: An offender arranges or facilitates the travel of the victim with a view to that person being exploited – this can be even where the victim consents to the travel, as they may have been deceived or unduly influenced.
1.5 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.
1.6 This policy applies to all persons working for us but we also expect the same high standards from all of our contractors, suppliers and other business partners and we are launching a specific supplier’s code of conduct which we expect our contractors, suppliers and other business partners to adhere to.
2. Responsibility for this policy
2.1 The EGO RESTAURANTS HOLDINGS Board of Directors has overall responsibility for ensuring this policy and its implementation complies with our legal and ethical obligations.
2.2 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
2.3 This policy will be reviewed by EGO RESTAURANTS HOLDINGS on a regular basis (at least annually) and may be amended from time to time. Any updates will be notified to employees and, via our website, to our contractors, suppliers and other business partners.
3. Compliance with the policy
3.1 You must ensure that you read, understand and comply with this policy.
3.2 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.
3.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.4 If you believe or suspect a breach of this policy has occurred, or that it may occur, you must report it as soon as possible (see paragraph 5 below).
3.5 If you are unsure about whether a particular act or event or set of circumstances, the treatment of workers more generally, or their working conditions within any part of our supply chains constitute any of the various forms of modern slavery, raise it with the Company Secretary at Head Office on 01204 205019
3.6 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.
3.7 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.
3.8 If you believe that you have suffered any detrimental treatment, you should immediately inform:
(a) the Company Secretary at Head Office 01204 205019
4. Breaches of this policy
4.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5. ACTIONS TO REPORT SUSPECTED MODERN SLAVERY
5.1 You must report concerns about suspected modern slavery associated with EGO RESTAURANTS HOLDINGS or our suppliers by reporting this:
(a) to the Company Secretary at Head Office on 01204 205019
June 2022