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ANTI-SLAVERY AND HUMAN TRAFFICKING

This statement sets out the steps taken by Sunseeker London Limited, company registration number 02875114 and its group companies, including Sunseeker Poole Limited, company registration number 067384406 and its group companies. (referred to as “we,” “us,” “our, ”the Company” “Sunseeker London Group”) pursuant to section 54, Part 5 of the Modern Slavery Act 2015 (Act).

We are committed to improving our practices to combat slavery and human trafficking, in accordance with the Modern Slavery Act 2015.

Organisation’s structure

We are distributors of Sunseeker motor yachts and we are a part of the Sunseeker London Group.
Our policies on slavery and human trafficking.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Our Anti-slavery Policy (Policy) reflects our commitment to acting ethically and with integrity in all our business relationships. Our Policy is designed to assist Sunseeker London Group to comply with the requirements of the Modern Slavery Act 2015.

Our Policy gives workers, contractors and other business partners guidance on slavery and human trafficking and the measures taken by the organisation to tackle slavery and human trafficking in its business and its supply chains.

Our suppliers (and their suppliers) are required to comply with all applicable laws, statutes, regulations and codes from time to time in force.
This statement has been approved by the board of Sunseeker London Group.

Policy statement

• Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, 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. 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 modern slavery is not taking place anywhere in our own business or in any of our supply chains.

• 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. We expect the same high standards from all of our contractors, suppliers and other business partners.

• 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.

• The company will not support or deal with any business knowingly involved in slavery or human trafficking. Our main suppliers are all UK registered and many have a long history with us. We consider our main risks to be thirdparty contract labour in the construction industry and caravan manufacturing.

• Many of our contractors publish their own policy and are members of global networks, which provide supplier risk management and compliance, and supplier visibility. Some of our suppliers, however, fall below the government threshold of having to publish their own policy. We recognise that supporting the business community and taking steps to help eradicate modern slavery should be adopted by all businesses no matter of size.

• This policy does not form part of any employee’s contract of employment and we may amend it at any time. However, failure to comply with this policy will result in disciplinary action, including dismissal for gross misconduct.

Risk assessment

• The Directors recognise our responsibility to meet human rights responsibilities and this is supported by the Company. We will be working to assess and respond to the risk of modern slavery and incidences of modern slavery and we will continue to publish and update when further progress has been made.

• We have internal procedures in place for procurement and carry out due diligence on all suppliers before allowing them to become a preferred supplier.

• During the year and throughout our review, we have found no areas of concern, instances of non-compliance or non-acceptance, however, we recognise that we need to continue to assess on an ongoing basis.

• We pledge to continue to audit our supplier chain, map out high-risk areas to improve our understanding of our suppliers’ policies and practices to combat Modern Slavery, to raise awareness of Modern Slavery and Human Rights and to affirm our zero-tolerance approach. We will continue to disclose our findings in future statements.

• We will continue to request acceptance of our anti-slavery policy and remove any supplier from our approved supplier list should any instances of modern slavery come to light.

Responsibility for the policy

• The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

• 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.

Compliance with the policy

• All individuals and organisations who deal with the Company must read, understand and comply with this policy.

• 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.

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

• 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.

• If you believe or suspect a breach of this policy has occurred or that it may occur you must notify the Company as soon as possible.

• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Company.

• 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. 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. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

Breaches of this policy

• Any individual / organisation who breach this policy will face disciplinary action, which could result in summary dismissal for misconduct or gross misconduct and / or immediate termination of contract.

• We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

This policy was last updated on 10 June 2019 by David Lewis, Managing Director
for and on behalf of Sunseeker London Limited (and the related group of companies)
10 June 2019

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