Modern Slavery Policy

1. Ethero Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
   
   
2. Ethero Ltd is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

Ethero Ltd provides appropriate training and awareness information for its entire staff. 

In particular:

• Our consultants, service teams & management receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
• Our consultants, service teams & management undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
  
  

3. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to their Branch Manager, Senior Management or Audit & Compliance Manager.

4. All our Senior Management team takes reports surrounding any form of abuse extremely seriously. They are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
   
   

• Working with the appropriate organisations to improve standards,
• Removing that organisation from our preferred supplier list,
• Passing details to appropriate law enforcement bodies.

5. We regularly monitor our risks in this area, including:
   
   

• The effectiveness of enforcement against suppliers who breach policies,
• The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
• The level of modern slavery training and awareness amongst our staff.

6. As part of our efforts in this area, we publish a modern slavery statement on a regular basis.

7. We would also recommend reading this in conjunction with our other policies, including our:
   
   

• Corporate social responsibility policy,
• Anti-bribery / corruption policy, and
• Whistle-blowing policy.
  
  

This policy was adopted in June 2017 and updated in June 2021 after being signed off by our Managing Director, Gareth Hughes. Senior Management reviews this policy on an annual basis.