Anti-Slavery Policy
Policy statement
StormHarvester Utilites Ltd is committed to conducting business in an ethical and honest manner and to implementing and enforcing business processes that provide Customer and Investor value. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, in every country in which we operate.
StormHarvester Utilites Ltd will constantly uphold all laws relating to quality and integrity in all the jurisdictions in which we operate. We are bound by the laws of the UK, for our conduct both at home and abroad.
StormHarvester Utilites Ltd recognises that employment principles are the cornerstone of any sustainable business albeit for individual domestic customer or in tendering for public contracts; also, that our business would face serious damage to our reputation if we fail to do exactly what we say we will do.
Who is covered by the policy?
This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies.
Any arrangements our company makes with a third party is subject to clear contractual terms, including provisions that require the third party to comply with minimum standards and procedures relating to employment.
Policy Statement
StormHarvester Utilites Ltd 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 that our suppliers will hold their own suppliers to the same high standards.
Modern Slavery and Human Trafficking
Modern slavery 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.
Commitments
We shall be 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 organization 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. The inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties – shall be standard practice. Furthermore, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, thereby setting out the minimum standards required to combat modern slavery and trafficking.
• Consistent with this approach we may require:
- Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
- Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
• 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 Code of Conduct.
• If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated (and whether that might represent the best outcome for those individuals impacted by the breach) to terminating such relationships and informing the relevant authorities.
Monitoring and reviewing
StormHarvester Utilites Ltd Directors are responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. Internal control systems and procedures designed to prevent transgressions may be subject to regular audits to ensure that they are effective in practice. Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
This policy does not form part of an employee’s contract of employment and StormHarvester Utilites Ltd may amend it at any time so to improve its effectiveness at combatting issues
effecting unethical employment.
Declaration
This is the Anti-slavery Policy of StormHarvester Utilites Ltd and as such is signed on behalf of
all the Directors
Signed: Jonathan Lavercombe
Dated: 12 April 2023
Position: Chief Operating Officer
