Modern Slavery and Human Trafficking Policy

1. Introduction

1.1. The purpose of this document is to provide a definition of the Anti-Slavery and Human Trafficking Policy for Anthem Management Limited.

1.2. Modern slavery is a crime and a violation of fundamental human rights. It is the practice of illegally transporting a person from one place to another, usually for the purpose of being sold into some form of slavery, e.g., servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

1.3. The Company has zero tolerance for modern slavery and trafficking in any form and 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.
  • 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.
  • Expecting the same standards from all our contractors, suppliers, and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude, whether adults or children.

2. Communication and Awareness

2.1. Training on this policy, and the risk our business faces from modern slavery in our supply chains, forms part of the induction process for all Associates who work for us, and regular updates will be provided, as necessary.

2.2. Our zero-tolerance approach to modern slavery must be communicated to all contractors, third-party suppliers, and business partners at the outset of our business relationship with them and reinforced as appropriate.

3. Breach of the Policy

3.1. Any Associate who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Any organisations working on our behalf who breach this policy will be terminated with immediate effect.

4. Responsibilities


4.1. The Company's Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. They will provide a slavery and human trafficking statement for each financial year.

4.2. The ELT have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

4.3. 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.


4.4. Associates must ensure that they have read, understand, and comply with this policy and carry out any training allocated to them.

4.5. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains are the responsibility of all those working for us or under our control. Associates must avoid any activity that might lead to or suggest a breach of this policy.

4.6. If Associates believe or suspect a breach of this policy has occurred or that it may occur, they must speak to their Line Manager or the General Counsel.

4.7. If unsure about whether a particular act, the treatment of workers, or working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, it should be raised immediately the Associate’s line manager or the General Counsel.

4.8. 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. We are committed to ensuring no one suffers any detrimental treatment because of reporting their suspicion that modern slavery of any form is or may be taking place in any part of our business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

4.9. If Associates believe that they have suffered any such treatment, they should inform the Talent Team immediately. If the matter is not remedied, then a formal Grievance can be submitted using the Grievance Procedure.

5. Application

5.1. This policy applies to all persons working for, or on our behalf of the Company, in any capacity, including Associates at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, and agents.

5.2. It also applies to Company contractors, external consultants, agencies, third-party representatives, and business partners, and anyone in our supply chain.

6. Review

6.1. This Policy will be reviewed annually or earlier as is necessary.

7. Associated Documents

7.1. GP 001 – Whistleblowing

7.2. Recruitment - Checks on the eligibility of employees

7.3. Code of Conduct

7.4. IHASCO Training for all Associates. (Levels may differ dependant on role)

7.5. HR 006 - Grievance Policy