Anti-Slavery and Human Trafficking Policy

Maxim World Anti-Slavery and Human Trafficking Policy

1. General Principles

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s freedom by another in order to exploit them for personal or commercial gain. Modern slavery is a crime and a violation of fundamental human rights.

Maxim World* (“MW”) complies with all of the laws of the countries in which it operates. Amongst these are the laws relating to anti-human trafficking and anti-slavery laws. MW has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not tolerated in our own business or any of our supply chains.

MW is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, in line with our disclosure obligations under the Modern Slavery Act 2015.

MW expects the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

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, service providers, suppliers, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. Compliance 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.

Therefore, you must ensure that you read and understand this policy. All our employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, service providers, suppliers, external consultants, third-party representatives and business partners, as well as anyone acting on behalf of MW must comply with this policy.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager or a company director 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 your manager or Director or report it in accordance with our Whistleblowing Policy as soon as possible.

Management at all levels are responsible for ensuring those reporting to them are aware of the issue of modern slavery and understand and comply with this policy. Any MW employee who has any questions in respect of this policy should address this to the management.

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.

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 your manager or director.

MW 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 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.

3. Communication and Awareness of this Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

4. Breaches of this Policy

Any breaches of this policy may result in MW taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.