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Anti slavery and human trafficking policy


SBL values human rights and is committed to ensuring that all business is conducted according to ethical, professional and legal standards in a fair, honest and open manner. We are committed to acting ethically and with integrity in all its business dealings and relationships and maintains effective systems and controls to enforce this policy, ensuring modern slavery is not taking place anywhere in the business or in any of its supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are also committed to 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. We expect the same high standards from all of 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, 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, external consultants, third-party representatives and business partners.



  1. The 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.
  2. The Human Resources department 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 procedures.
  3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Guidance on the policy can be obtained from the Human Resources team.


  1. We prohibit all forms of Modern Slavery and seeks to educate and influence our employees and suppliers to ensure that no form of Modern Slavery is taking place in its own business operations or in its supply chain. Our employees, contractors, subcontractors, vendors, suppliers, partners, representatives, agents and others through whom GWA conducts business must not engage in any practice that constitutes any form of Modern Slavery. This includes, but is not limited to, the following activities:
    • Engaging in any form of trafficking in persons.
    • Using forced labour in the performance of any work.
    • Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
    • Using misleading or fraudulent practices during the recruitment or offering of employment/contract positions to candidates; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs, any significant cost to be charged to he candidate, and, if applicable, the hazardous nature of the work.
    • Using recruiters that do not comply with local labour laws of the country in which the recruiting takes place.
    • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.
  2. We have in place an open and transparent whistleblowing process and a formal grievance redressal framework that enables everyone, including partners, contractors and employees, to raise their concerns at a single platform with complete confidentiality and has strict ‘non-retaliation’ policy to safeguard the interests of whistle-blowers
  3. We seek to raise awareness so that our colleagues know what we are doing to promote appropriate welfare practices.


  1. You must ensure that you read, understand and comply with this policy.
  2. 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. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  3. You must notify HR team as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
  4. 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.
  5. 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 the HR Team.
  6. We aim 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. If you believe that you have suffered any such treatment, you should inform the HR Team immediately.



  1. We provide specific training to those staff members who are involved in managing recruitment and our supply chains.
  2. Guidance on this policy forms part of the induction process for all individuals who work for us and will be provided otherwise as necessary.
  3. We offer multiple mandatory trainings through various forums and workshops to our suppliers and employees on anti-slavery and anti-human trafficking, specifically to identify such issues in the supply chain and respond in accordance with the applicable laws.
  4. Our suppliers are also required to assess their businesses and supply chain to ensure compliance with the provisions of the Modern Slavery Act, anti-human trafficking and other Human Rights requirements as incorporated under this Statement



  1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
  2. We require suppliers to ensure that their employees are hired on their own free will and that they must prohibit forced, bonded, or any other form of compulsory labour such as slavery or trafficking, transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services in all of their operations. If suppliers are found to be non-compliant with anti-slavery or anti-human trafficking practices in their business, or knowingly in their supply chain, we may terminate the contract for services with immediate effect, including future blacklisting of the supplier concerned taking into account the extent of non-compliance and pursue legal remedies against the supplier concerned



We will review our Anti-slavery policy regularly. We will provide information and/or training on any changes we make.

Suggestion/Complaints may please be directed to [email protected]

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