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Modern Slavery Policy

1. Introduction

At Surplus, we are committed to preventing modern slavery and human trafficking within our operations and supply chains. This policy outlines our approach to ensuring that these practices do not occur within our business or supply chain relationships.

2. Definition of Modern Slavery

Modern slavery encompasses slavery, servitude, forced or compulsory labor, and human trafficking. We recognize that these activities are a severe violation of fundamental human rights. We are committed to acting ethically and with integrity in all our business dealings to prevent such practices.

3. Our Commitment

3.1 Zero Tolerance

We maintain a zero-tolerance approach to modern slavery and human trafficking. We are dedicated to ensuring that neither practice exists in our supply chains or within any part of our business.

3.2 Compliance

We fully comply with all relevant laws and regulations pertaining to modern slavery and human trafficking in the jurisdictions where we operate.

4. Due Diligence Processes

4.1 Supplier Vetting

We conduct due diligence on all new suppliers and regularly review existing ones to ensure their compliance with our standards regarding modern slavery. This includes an assessment of their labor practices, working conditions, and adherence to local and international laws.

4.2 Risk Assessment

We regularly assess the risks of modern slavery within our supply chains, evaluating the geographical locations and sectors in which our suppliers operate to identify and mitigate potential risks.

4.3 Audits

Where possible, we audit our suppliers to ensure compliance with our policies and standards on modern slavery. These audits may be conducted either directly by us or by third-party auditors.

5. Supplier Code of Conduct

We have established a Supplier Code of Conduct that outlines our expectations for the prevention of modern slavery. Our suppliers are required to:

  • Comply with all applicable laws and regulations relating to modern slavery and human trafficking.
  • Ensure that all work is voluntary, and workers are not coerced, threatened, or subjected to forced labor.
  • Provide safe and healthy working conditions.
  • Pay fair wages and comply with applicable wage laws.
  • Respect the rights of workers to freely associate and bargain collectively.

6. Training and Awareness

We provide training and resources to our employees to ensure they understand the risks of modern slavery and how to identify and address these risks in our business and supply chains. This includes:

  • Regular training sessions on modern slavery and human trafficking.
  • Access to resources and guidelines on ethical labor practices.
  • Raising awareness of the importance of preventing modern slavery.

7. Reporting and Whistleblowing

We encourage our employees, suppliers, and stakeholders to report any concerns or suspicions regarding modern slavery in our business or supply chains. Reports can be made confidentially through the following channels:

All reports will be thoroughly investigated, and appropriate action will be taken where necessary.

8. Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery. This includes regularly reviewing and updating our policies, procedures, and training programs to ensure they remain effective and aligned with industry best practices.

9. Governance

Our senior management team is responsible for overseeing the implementation and effectiveness of this policy. They ensure that adequate resources are allocated to prevent modern slavery and that our practices are regularly reviewed and updated as needed.

10. Review of Policy

This Modern Slavery Policy will be reviewed annually to ensure its relevance and effectiveness. Any updates will be communicated to our employees, suppliers, and stakeholders.

11. Contact Us

If you have any questions or concerns regarding this Modern Slavery Policy, please contact us at: