Anti-Slavery Policy

Last Updated: 14.10.22 

Modern slavery is a crime and a violation of fundamental human rights. It takes many forms,  including slavery, servitude, forced and compulsory labour, and human trafficking, all of  which involve the deprivation of a person’s liberty by another to exploit them for personal or  commercial gain. 

Hanley Consulting (Hanley Health Ltd.) takes a zero-tolerance approach to modern slavery,  and we are committed to acting ethically and with integrity in all our business dealings and  relationships, as well as implementing and enforcing effective systems and controls to ensure  modern slavery does not exist anywhere in our own business or in any of our supply chains. 

We are also committed to ensuring transparency in our own operations and in our approach to  combating modern slavery throughout our supply chains, in accordance with our disclosure  obligations under the Modern Slavery Act. 

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

This policy applies to all individuals who work for Hanley Consulting 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 is not part of any employee’s employment contract, and we reserve the right to  change it at any time. 

Policy Responsibilities 

The Hanley Group is ultimately responsible for ensuring that this policy conforms with our  legal and ethical commitments, as well as that all people under our control abide by it. 

Hanley Health Ltd. oversees implementing this policy daily, monitoring its usage and  effectiveness, dealing with any questions about it, and reviewing internal control systems and  processes to ensure they are successful in combating modern slavery. 

Management at all levels is responsible for ensuring that people reporting to them understand  and comply with this policy, as well as that they get proper and ongoing training on it and the  subject of modern slavery in supply chains.

You are welcome to comment on this policy and offer ways to improve it. Any comments, suggestions or queries are encouraged and should be addressed to Paul  Harvey. 

Policy Compliance 

You must read, understand, and enforce this policy. The prevention, identification, and  reporting of modern slavery in any element of our company or supply chains is the duty of  everyone who works for us or is under our authority. 

You must refrain from engaging in any action that might lead to or imply a violation of this  policy. 

If you feel or suspect that a conflict with this policy has happened or will occur in the future,  you must contact your line manager or a business director as soon as possible. 

You are urged to express concerns about any issue or suspicion of modern slavery in any  aspect of our business or any supplier tier’s supply chain as soon as possible. 

If you feel or suspect a violation of this policy has occurred or may occur, you must alert  your line manager or a company director as soon as possible or report it in accordance with  our Whistleblowing Policy. 

You should note that where appropriate, and with the welfare and safety of local workers as a  priority, we will give support and guidance to our suppliers to help them address coercive,  abusive, and exploitative work practices in their own business and supply chains. 

If you have any doubts about whether a specific act, the treatment of employees in general, or  their working circumstances inside any tier of our supply chains represents any of the  numerous types of modern slavery, please contact your line manager or a company Director. 

We want to promote transparency and will assist anybody who expresses serious concerns in  good faith under this policy, even if those worries turn out to be incorrect. We are dedicated  to ensuring that no one experiences any adverse treatment as a result of reporting in good  faith their concern that modern slavery in any form is or may be occurring in any section of  our own business or in any of our supplier networks. 

Dismissal, disciplinary action, threats, or other unfavourable treatment as a result of voicing a  concern is considered detrimental treatment. 

If you suspect you have been subjected to such treatment, you should immediately notify  your line manager. If the problem is not resolved, and you are an employee, you should file a  formal complaint.

Communication & Awareness 

Training on this policy, as well as the threat our company faces from modern slavery in its  supply chains, is part of the induction process for all new employees, and updates will be  offered through established channels of communication between the company and you. 

Our zero-tolerance stance to modern slavery must be conveyed to all suppliers, contractors,  and business partners from the beginning of our commercial engagement with them and  reinforced as needed subsequently. 

Policy Breaches 

Any employee who violates this policy may face disciplinary action, which might result in  dismissal for misconduct. If other persons or organisations working on our behalf violate this  policy, we reserve the right to terminate our relationship with them with immediate effect.

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