Last Updated: 02 September 2024

  1. Purpose

    This Modern Slavery Policy outlines GC Partner’s commitment to identifying, preventing, and mitigating risks of modern slavery and human trafficking in its operations and supply chains. GC Partner’s is dedicated to conducting business ethically and with integrity, ensuring compliance with all relevant legislation and regulations.

  1. Scope

    This policy applies to all employees, contractors, suppliers, and other stakeholders engaged with GC Partners. It covers all business operations and supply chains, both domestic and international.

  1. Definitions

    Modern Slavery: Refers to situations where coercion, threats, or deception are used to exploit individuals and undermine their freedom. This includes human trafficking, forced labour, child lab or, and debt bondage.

    Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons through the use of force, coercion, or other means for the purpose of exploitation.

    Forced Labor: Work that is performed involuntarily under the threat of penalty.

  1. Policy Statement

    GC Partners is committed to:

    • Zero Tolerance – We have a zero-tolerance approach to modern slavery and human trafficking in any part of our business or supply chains.
    • Compliance: Complying with all applicable laws and regulations relating to modern slavery, including the Modern Slavery Act 2015.
    • Due Diligence: Implementing and maintaining effective systems and controls to ensure modern slavery is not taking place within our operations and supply chains.
    • Risk Assessment: Regularly assessing the risks of modern slavery in our business and supply chains and taking appropriate steps to address any identified risks.
    • Training and Awareness: Providing training and raising awareness among our employees, suppliers, and stakeholders about the risks of modern slavery and how to mitigate them.
    • Reporting and Transparency: Encouraging employees and stakeholders to report any concerns related to modern slavery and human trafficking and ensuring transparency in our efforts to combat these issues.

  1. Responsibilities

    • Board of Directors: Overall responsibility for ensuring this policy complies with legal and ethical obligations.
    • Managers and Supervisors: Ensuring those reporting to them understand and comply with this policy.
    • Employees: Reporting any suspicions or concerns regarding modern slavery or human trafficking.

  1. Due Diligence Processes

    • Supplier Audits: Conducting regular audits of our suppliers to assess their compliance with our modern slavery standards.
    • Contractual Obligations: Including specific clauses related to modern slavery and human trafficking in all contracts with suppliers.
    • Monitoring and Review: Continuously monitoring and reviewing our policies and practices to ensure they remain effective in combating modern slavery.

  2.  Training and Awareness

    • Providing training to employees on the risks and indicators of modern slavery.
    • Raising awareness through internal communications and educational materials.

  3. Reporting Concerns

    • Whistleblowing Policy: Encouraging employees and stakeholders to report concerns through our whistleblowing channels.
    • Confidentiality: Ensuring that all reports are treated confidentially and that individuals who report concerns in good faith are protected from retaliation.

  4. Review and Update

    This policy will be reviewed annually by the Board of Directors and updated as necessary to ensure its effectiveness in preventing modern slavery and human trafficking.

  5. Approval

    This policy has been approved by the Board of Directors of GC Partners and is endorsed at the highest level of our organisation.

    By adhering to this policy, GC Partner’s demonstrates its commitment to eradicating modern slavery and ensuring ethical practices in all aspects of its operations.