This policy does not form part of any employee’s contract of employment and may be varied by the Company or replaced at any time.

1. PURPOSE

1.1. The purpose of this policy is to ensure that all suppliers to SAS are fully understanding, committed and compliant to the titled policy and in doing so confirm their acknowledgement and agreement to the requirements of the Act as well as confirming both receipt and acknowledgement of this policy.

1.2. SAS Holdings Limited 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.

1.3. SAS Holdings Limited maintains relationships with many different organisations in its supply chain, as well as directly employing large numbers of people. In the light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, will aim to 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.

1.4. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we 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 suppliers will hold their own suppliers to the same high standards.

2. SCOPE

2.1. 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, sponsors, or any other person associated with us, wherever located.

3. DEFINITIONS

3.1. KPI’s – Key Performance Indicators – are the method of indicating and recording progress towards an intended result.

3.2. Whistleblowing – A defined method of highlighting breaches of unlawful or immoral activity.

4. QUALIFICATION

4.1. 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, sponsors, or any other person associated with us, wherever located (collectively referred to as workers in this policy).

5. RESPONSIBILITIES

5.1. To mitigate risks, the Procurement team engages all relevant due diligence checks when new suppliers are onboarded. The Procurement team will also review our supply chains in order to identify risk of slavery and human trafficking. The HR department will review people related activities to ensure that processes such as recruitment are free from human trafficking and slavery. The Head of Compliance will be responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.

5.2. To fully comply with this policy, all relevant employees are regularly trained on the issues concerning modern slavery.

5.3. ORGANISATION ROLES & RESPONSIBILITIES

5.3.1. Directors have overall responsibility for ensuring that SAS Holdings Limited policy complies with its legal and ethical obligations.

5.3.2. The HR team have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and dealing with any queries about it.

5.3.3. Procurement Managers are responsible for auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

5.3.4. 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.

5.3.5. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the HR Department.

6. CONTACT SAS

6.1. Contact can be made with the above persons responsible for upholding this policy through the following address and telephone number:
Head office address:
EMAC House, Unit 28, Suttons Business Park, Sutton Park Avenue, Earley, Reading, RG6 1AZ
Phone Reception: +44 (0) 118 929 0900

7. ESCALATION MATRIX RESPONSIBILITY

7.1. Should there be a need to escalate an issue for urgent resolve then the following matrix shows the agreed route for address especially whereby the dispute is threatening either party’s ability to perform and/or receive satisfaction to terms:
Title: Head of HR → Head of Quality & Procurement → CEO

8. RELEVANT POLICIES & PRACTICES

8.1. SAS operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

8.1.1. The Group’s policy on whistleblowing encourages all its workers, customers and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

8.1.1.1. The Company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can refer to the Group.

8.1.1.2. The whistleblowing policy is available on the Company intranet. The nature of the whistleblowing policy should encourage workers to disclose concerns about any wrongdoing in the workplace, including modern slavery concerns.

8.1.2. The Company also operates a recruitment policy and ensures that our agency suppliers also comply with this policy, to prevent people from being forced to work under the threat of punishment.

8.1.3. SAS’s supplier due diligence programme extends to assessing risks of modern slavery occurring in our supply chain. We follow a risk-based approach to deciding when and which suppliers to audit, with a particular focus on those industries and countries which have been identified by the Global Slavery Index as being at higher risk.

9. CHILD LABOUR

9.1. We will not work with any supplier who employs or uses child labour. Child labour includes any work performed by a child who is under the age of completion of compulsory education, or if this age is not clearly determinable, under 16 years of age.

9.2. For young persons between the minimum working age and 18 years, we expect our suppliers to ensure that the working hours of young persons do not interfere with their education and that their health, safety and welfare is appropriately protected.

10. FORCED LABOUR

10.1. We expect our suppliers not to employ workers using any form of forced labour. This includes forced labour in which workers are bonded to an employer through debt, often incurred in the recruitment process, and labourers who have migrated from other regions or countries to earn money.

10.2. Workers must not be required to pay excessive fees or deposits as a condition of employment and must be free to leave employment by giving reasonable notice. Workers must not be required to hand over identity documents as a condition of employment.

11. RECRUITMENT

11.1. We expect our suppliers to use responsible recruitment practices that respect migrants and other vulnerable worker groups, and not to engage recruitment agencies that charge workers fees.

11.2. Workers must have a written employment contract or agreement that is provided in a language they understand, so they fully understand their terms of employment.

12. HEALTH AND SAFETY

12.1. We expect our suppliers to provide workers with safe and healthy working conditions that comply with applicable laws and regulations. This includes providing appropriate facilities and training, as well as performing risk assessments and taking corrective action to manage workplace hazards.

13. WAGES

13.1. We expect our suppliers to pay workers at least the statutory minimum wage.

13.2. Workers must receive a regular and timely payment of wages. In cases where it is the local norm or legal requirement for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required.

13.3. We are a Living Wage employer (UK) and as a result require all of our suppliers and contractors to abide by the rate set by the Living Wage org which is reviewed annually.

14. WORKING HOURS

14.1. We expect suppliers to monitor the working hours of their employees and ensure that they do not breach legal requirements and that the required rest days are provided.

15. FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING

15.1. The Company recognises the importance of open communication and direct engagement between workers and management.

15.2. We expect our suppliers to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference, or reprisal; and to recognise and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing.

15.3. Suppliers also must respect any legal right of workers to bargain collectively.

16. DISCRIMINATION

16.1. We expect our suppliers not to subject workers to discrimination in employment, including hiring, compensation, advancement, discipline, termination, or retirement on the basis of any legally protected characteristic or status such as age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, or sexual orientation.

17. APPRENTICESHIPS

17.1. Suppliers are encouraged to participate in appropriate workplace apprenticeship programmes that comply with applicable laws and regulations.

18. RESPONSIBILITY FOR ETHICAL WORKING PRACTICES

18.1. We expect our suppliers to:

18.1.1. not enter into unfair practices to compete for our business and expects its suppliers will make purchasing decisions objectively based on price, delivery, and other relevant practices.

18.1.2. ensure appropriate policies are put in place to ensure the prevention, detection, and reporting of bribery; and

18.1.3. pay suppliers on a timely basis.

19. DOCUMENT OWNER AND APPROVAL

The HR Department is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with International Standards and regulatory requirements.

This policy was approved by the Board of Directors and is issued on a version-controlled basis. The current version of this document is available to all members of staff via the company SharePoint and is published as required.

Alyn Gammon
Chief Executive Officer

Review History