Anti Slavery and Human Trafficking Policy
1. Policy
Datalaw maintains relationships with a wide range of organisations and employs considerable numbers of people. In line with the Modern Slavery Act 2015, the Human Rights Act 1998, evolving Home Office statutory guidance (2023–2024), and industry best practice for 2025–2026, we continually review our compliance and risk-management processes to ensure robust prevention of modern slavery and human trafficking in any part of our operations or supply chains.
This Policy underpins our approach and informs our annual Modern Slavery and Human Trafficking Statement.
Datalaw requires all individuals and organisations with or seeking a business relationship with us to familiarise themselves with this Policy and our public Anti-Slavery Statement, and to act in full accordance with their requirements at all times.
Datalaw is committed to opposing modern slavery in all its forms and preventing its occurrence through effective systems, governance, and due diligence. We adopt a zero-tolerance approach to modern slavery and expect the same from all employees, suppliers, contractors, partners, and stakeholders.
2. Aims
Modern slavery is a criminal offence under the Modern Slavery Act 2015 and may include servitude, forced or compulsory labour, debt bondage, and human trafficking. All forms involve the exploitation and deprivation of an individual’s liberty.
This Policy aims to prevent opportunities for modern slavery and human trafficking across all Datalaw operations and supply chains.
Datalaw is committed to:
- Acting ethically and with integrity in all business relationships.
- Maintaining effective systems, controls, and due-diligence processes to ensure that modern slavery is not occurring anywhere in our business or in the businesses of our suppliers.
- Meeting and exceeding emerging expectations for transparency, supplier verification, and ESG-aligned risk management.
For the purposes of this Policy, Modern Slavery has the meaning given in the Modern Slavery Act 2015.
3. Scope
Datalaw is committed to transparency in our business and supply chains and to meeting evolving disclosure expectations under the Modern Slavery Act 2015 and accompanying guidance.
We expect the same high standards from all business partners. Our contracting processes include explicit prohibitions against:
- Forced, compulsory, or trafficked labour
- Use of child labour in contravention of international and UK standards
- Any form of servitude or exploitation
All employees must familiarise themselves with this Policy and associated procedures and conduct business in a way that prevents any opportunity for modern slavery to occur. Compliance with this Policy forms part of all employment contracts.
To underpin this Policy, Datalaw will implement and maintain the following measures:
- Conduct annual modern-slavery risk assessments, identifying higher-risk areas within our operations and supply chains and prioritising mitigation.
- Maintain a Supplier Code of Conduct that reinforces our zero-tolerance position and outlines the standards we expect from all third parties.
- Engage and communicate with all business partners to reinforce expectations and understand the measures they take to prevent modern slavery.
- Introduce screening and due-diligence processes, including pre-engagement checks, self-assessment questionnaires, and supply-chain mapping where appropriate.
- Include contractual clauses requiring suppliers to comply with this Policy, implement robust anti-slavery controls, notify us immediately of any breach or suspected breach, and permit auditing when requested.
- Use technology and data monitoring tools, where appropriate, to assess supply-chain risk, aligned with evolving industry best practice.
- Provide regular training to employees and managers on identifying and preventing modern slavery.
4. Responsibility
Ultimate responsibility for preventing modern slavery rests with the Board of Directors, who ensure this Policy complies with legal, ethical, and regulatory obligations.
Managers are responsible for ensuring the Policy is understood by teams, ensuring staff receive appropriate and regular training, and reporting concerns promptly and appropriately.
All employees have a responsibility to remain vigilant and report concerns without delay.
5. Concerns
Employees should raise concerns where they suspect that modern slavery may be occurring. Examples include (but are not limited to):
- Suspicion that someone acting for Datalaw is exploiting another person.
- Suspicion that a supplier, contractor, or partner is engaging in exploitative practices.
- Being approached to participate in actions that could breach the Modern Slavery Act 2015.
- Receipt of information indicating a person may be preparing to commit or has committed a modern-slavery offence.
For further guidance, refer to the Whistleblowing Policy.
6. Protection of Those Raising Concerns
Datalaw encourages openness and will support any individual who raises a genuine concern in good faith, even if the concern is later found to be mistaken.
We are committed to ensuring that no one suffers detrimental treatment for reporting concerns. Detrimental treatment includes dismissal, disciplinary action, threats, or any unfavourable treatment. Anonymous reporting is permitted, although identified disclosures may allow more effective investigation.
Malicious or knowingly false allegations may result in disciplinary action.
7. Internal Reporting
Employees should normally raise concerns with their immediate Line Manager or Contract Manager. Where that is not appropriate due to sensitivity or involvement of management, concerns should be raised with a member of the Senior Leadership Team (SLT), including the Managing Director, Commercial Director, or Quality Managers.
A Line Manager receiving a disclosure must refer the matter to an SLT member.
8. External Reporting
Where an employee feels unable to report internally, external options include Protect (the UK whistleblowing charity) on 020 3117 2520 or info@protect-advice.org.uk. Employees may also report to prescribed authorities listed by the UK Government (GOV.UK – Whistleblowing: List of Prescribed Persons).
9. Investigating Procedure
All concerns will be reviewed to determine whether an investigation is required, the appropriate form of investigation, and the appointment of an Investigating Officer.
An investigation may include obtaining full details and clarification of the concern, interviewing relevant individuals and witnesses, securing evidence in an admissible format, keeping the discloser informed where appropriate, and reporting findings to senior management or the Board, depending on severity.
Confidential records will be maintained for monitoring and compliance purposes.
10. Timescales
Investigations will be conducted as promptly as possible, taking into account the nature and complexity of the disclosure.
11. Outcomes
Depending on findings, outcomes may include no further action, internal process improvements, corrective actions with suppliers, termination of supplier contracts, disciplinary action against employees, or referral to police or regulatory authorities.
12. Communication and Awareness
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of relationships and reinforced through ongoing engagement. Training and awareness sessions will be provided regularly to ensure understanding of modern-slavery risks and responsibilities.
13. Review
This Policy will be reviewed annually or earlier if required by legislation, regulatory changes, or significant changes in the business. Updates will be approved by the Board of Directors.
|
Reviewed Date |
04th December 2025 |
Next Review Due Date |
04th December 2026 |
|
Reviewed by |
Sarah Parker |
Signature |
Sarah Parker |