Modern slavery and human trafficking 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 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 and/or human trafficking is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and human trafficking 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.
The purpose of this policy is to:
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
The leadership of Visibly has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The General Counsel has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery and human trafficking in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the general counsel. Please direct any such queries to legal@visiblyhq.com
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery and human trafficking 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.
You must notify your manager as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery and/or human trafficking in any parts of our business or supply chains of any supplier at the earliest possible stage.
If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible.
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 and/or human trafficking, raise it with your manager immediately.
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 and/or human trafficking 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 contact your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure as outlined in the Grievance Policy.
Training on this policy, and on the risk our business faces from modern slavery and human trafficking in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our commitment to addressing the issue of modern slavery and human trafficking in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them through use of our standard form questionnaire and reinforced as appropriate on an ongoing basis.
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review. To facilitate this process, we maintain a dedicated Gifts and Hospitality Register.
You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are 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.
You must notify your line manager or the confidential helpline as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business.
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your line manager or the Legal Team.
If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your line manager or the Legal Team.
Training on the subject matter of this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Last review: Feb 2024
