Foreword by Owen Varley – Managing Director

This policy sets out the general rules and principles to which we, at MMD, adhere. It will be communicated to all employees and overseen by the MMD Board, as well as relevant business partners and other necessary individuals and entities. Those who work in areas within our business identified as being particularly high risk will receive additional training and support in identifying and preventing corrupt activities. This policy explains the procedures through which MMD can maintain high ethical standards and protect its reputation in accordance with the obligations under the Modern Slavery Act 2015.

Its successful implementation requires proactive adoption at the following levels: As an employee of MMD, you are required to read and understand all aspects of this policy, and abide by it.

Ensuring overall compliance with the requirements of this policy is the responsibility of the MMD Board, which will assist with continuous refreshing and reinforcing of this policy via application, guidance and monitoring.

1.0  Modern Slavery Act Transparency Policy Statement

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, agents, contractors and suppliers. MMD strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect and will ensure that our suppliers will hold their own suppliers to the same high standards.

2.0  Definition

Modern slavery, as defined by the Modern Slavery Act 2015, is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

3.0  Commitments

We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with our risk-based approach we may require:
    • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with the policy.
    • suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to this policy.
  • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our policy.
  • If we find that individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action.