1. Introduction

GWI  is committed to preventing modern slavery and human trafficking in all its forms. This policy delineates our strategy and approach to ensure the absence of modern slavery within our business operations and supply chain. This policy is aligned with the requirements of the Modern Slavery Act 2015 (the “Act”) and reflects our continued commitment to ethical business practices. 


2. Policy statement

2.1. Modern slavery is a criminal offence and a violation of fundamental human rights. It takes various forms, such as forced labour, debt bondage, human trafficking, and child labour, all of which deprive a person's liberty by another, solely in order to exploit them for personal or commercial gain. We 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 organisation or in any of our supply chains.

2.2. We are committed to ensuring transparency within our own organisation and in our strategy to combat modern slavery throughout our supply chains, and to remain consistent with the disclosure obligations under the Act. In turn, we expect the same high standard of care and conduct from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we expect that our suppliers will hold their own suppliers to the same high standards.


3. About the policy

3.1. The purpose of this policy is to:

3.1.1. set out GWI’s responsibilities,and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and

3.1.2. provide information to those working for and on our behalf, on how to identify and report concerns regarding modern slavery and human trafficking.

3.2. This policy applies to all GWIers, including but not limited to GWI employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives. We also expect our business partners to comply with the policy.

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


4. Responsibility of this policy

4.1. The board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2. The VP, Head of Legal has 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 guidance on it and the issue of modern slavery in supply chains.  

4.4. All employees are expected to understand and comply with this policy, reporting any concerns regarding modern slavery.


5. Your responsibilities and how to raise a concern

5.1. You must ensure that you read, understand and comply with this policy. 

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

5.3. GWI encourages a culture of transparency and accountability. All employees, suppliers, and stakeholders are encouraged to report any concerns or suspicions of modern slavery as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future. This includes raising concerns about any issue or suspicion of modern slavery in any parts of the organisation or supply chains of any supplier at the earliest possible stage.

5.4. If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify our VP, Head of Legal as soon as possible.

5.5. If you are unsure about whether a particular act or 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.

5.6. 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 organisation or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have experienced such treatment, promptly inform the People Team. If the matter is not remedied, employees can formally address the situation by raising a concern via our Grievance Procedure, available on GWIU.


6. Training and communication

6.1. Education, guidance and training on this policy is provided on a regular basis.

6.2. Our commitment to addressing the issue of modern slavery in our organisation and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.

6.3. GWI will publish an annual Modern Slavery Statement on its website, www.gwi.com detailing the actions taken to prevent and eradicate modern slavery within its operations and supply chains, as required by law.


7. Breaches of this policy

7.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

7.2. We may terminate our relationship with other individuals and organisations working on our behalf or those in our supply chain that have adopted this policy, if they breach this policy.