employees, contractors, officers, apprentices, casual and agency workers.
Date of implementation
Status and monitoring
Chris/Barry Fuller. Annually
A HR representative of the Company may be involved in the management, application and interpretation of this policy.
As a Group, Bates maintains relationships with many different organisations in its supply chain, as well as employing directly large numbers of people. In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015. We have reviewed our existing compliance and risk management processes to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains. The policy below underpins our approach.
Bates has adopted a statement of our corporate value on the prevention of modern slavery and human trafficking. The value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.
We expect all or who have, or seek to have, a business relationship with Bates and/or any member of our Group, to familiarise themselves with our anti-slavery value and to act at all times in a way which is consistent with our anti-slavery value.
As part of our culture of good governance for good business, at BATES GROUP we operate to a set of core values which reflect our relationships with our principal stakeholder groups: customers, manufacturers, shareholders, suppliers and team members. We adopt a behavioural value for all our business relationships, reflecting our attitude to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings.
Our attitude to modern slavery is: zero tolerance.
Bates Group 12th April 2022
(i) conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas;
(ii) engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses;
(iii) Where appropriate, as informed by our risk assessment, seek to introduce supplier pre- screening (for example as part of our tender process) and self-reporting for our suppliers on safeguarding controls;
(iv) Introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
• You suspect a person acting on behalf of Bates Group or one of our businesses is seeking to exploit another in a way which could amount to modern slavery;
• You suspect that a person acting on behalf of one of our suppliers is seeking to exploit another in a way which could amount to modern slavery;
• You have received an approach from a person acting on behalf of Bates Group or one of our businesses who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;
• You have information which leads to the rational conclusion that a person acting on behalf of Bates Group or one of our businesses or suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.
For more information on modern slavery please call the helpline 0800 0121 700 or visit www.modernslaveryhelpline.org
The Company encourages members of the public or people not employed by us to write, in confidence, to the Company Secretary to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.
Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Board of Directors on regular basis (at least annually) and may be amended from time to time. This Policy will be used to inform our Statement on Slavery and Human Trafficking.