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MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT

STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, 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. Romans International 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 and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our business.

We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout. We expect the same high standards from all our suppliers and other business partners.

This policy applies to all Romans International Limited employees, contractors, extern al consultants and third­ party representatives.

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

Everyone is responsible for ensuring they understand and comply with this policy.

Training on this policy will be provided so everyone understands the signs of modem slavery and what to do is they suspect that it is taking place within our supply chain.

COMPLIANCE WITH THE POLICY

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

The prevention, detection and reporting of modern slavery in any part of our business is the responsibility of all those working for Romans International Limited. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

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

You should raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest stage and this can be reported in accordance with our Whistleblowing Policy if you so wish.
We aim to encourage openness and will support anyone who raises concerns in good faith under this policy, even if they turn out to be a mistake. If you believe you have suffered any mistreatment as a result of raising a concern, you should inform your manager or Human Resources immediately.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

TRAINING

We invest in educating our employees to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our Induction programme employees are encouraged to identify and report any potential breaches of the company’s anti-slavery and human trafficking policy.

 

RISK ASSESSMENT

The Board has ultimate accountability for managing modern slavery risk, and its approach is integrated into the broader approach to business conduct and risk management. It is considered within one of its principal risks, bribery and corruption, and takes into account the nature of the Group’s business activities, the application of group policies, and the markets and geographies in which the Group operates. Overall, the Group considers its exposure to modern slavery and human trafficking risk to be low.

 

APPLICATION IN THE GROUP

All operating subsidiary companies are required to fully implement the principles of the Policy and must comply with it and remain compliant with UK legislation and to demonstrate the Group’s commitment to combatting slavery and human trafficking practices in its supply chains. It is the responsibility of each operating subsidiary company’s Director(s) to ensure that this policy and approach is adopted through their organisation to the extent relevant and appropriate to their operating subsidiary company. They have the primary responsibility for implementing the policy, monitoring its use and effectiveness, dealing with any queries about it, and ensuring effective internal control systems and procedures are effective in countering modern slavery.

 

OPERATING SUBSIDIARY COMPANY STATEMENTS

Due diligence in the supply chain, further risk assessment, measuring effectiveness, and training and awareness for employees is carried out at operating subsidiary company level and more detail can be found in those statements. The following operating subsidiary companies publish their Slavery and Human Trafficking Statements on their respective websites:

 

This statement is made in accordance with the reporting requirements of Clause 54, part 6 (1) of the UK Modern Slavery Act for the year ending 31 December 2020.

This statement was approved by P A Jaconelli, Director

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