Modern Slavery and Human Trafficking Policy

Policy statement

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, 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.

The Company has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking in our corporate activities. We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015 – http://www.legislation.gov.uk/ukpga/2015/30/section/54/enacted. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.

The Company also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

Policy Scope

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, casual workers, directors, agency workers, volunteers, agents, contractors, consultants and business partners.

CTS (GB) Ltd are a specialist in multi-modal transport and global logistics for government and defence, including UK Section 5 prohibited Firearms, Explosives and Security Sensitive items. We operate across Europe and continually monitor countries of high risk, such as Romania, Greece, Italy, Cyprus and Bulgaria.

Responsibility for the policy

The Senior Leadership Team has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

The Compliance Manager has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains. Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control.  You are required to avoid any activity that might lead to a breach of this policy. Steps may be taken against suppliers that do not meet the required standards, which could include a request to take action to improve, and or, termination of the business relationship if improvement is not forthcoming.

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager and report it in accordance with the Company’s Disclosures in the Public Interest Policy.  You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 or online at www.modernslaveryhelpline.org for further information and guidance.

The Company aims 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. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training and communication

Training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as part of their induction training and thereafter as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them and will form part of CTS supplier/sub-contractor/business partner accreditation process.  Where possible, CTS will use suppliers where an external accreditation with a regulated body provides assurance of compliance with the Modern Slavery Act 2015 (for example IATA)

Breach of the policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.