Anti-Slavery and Human Trafficking Policy

Infinics Limited
Effective Date: 17th September 2019
Reviewed: 17th September 2024

1. Policy Statement

Infinics Limited is committed to preventing modern slavery, human trafficking, forced labour, and exploitation of any kind within our business and our supply chains. We have a zero-tolerance approach to slavery and human trafficking and are dedicated to acting ethically and with integrity in all our business relationships.

This policy outlines our responsibilities and procedures in ensuring compliance with the Modern Slavery Act 2015 and applies to all employees, contractors, consultants, suppliers, and partners working with or on behalf of Infinics Limited.

2. Purpose

The purpose of this policy is to:

  • Define modern slavery and explain its different forms
  • Set out our commitment to combating it
  • Provide guidance on identifying and reporting suspected cases
  • Establish clear responsibilities across the business

3. Scope

This policy applies to:

  • All employees, directors, and officers of Infinics Limited
  • Contractors, agency workers, freelancers, and consultants
  • Suppliers, vendors, and any third parties with whom we do business

4. What is Modern Slavery?

Modern slavery includes:

  • Human trafficking – arranging or facilitating the travel of individuals with a view to exploiting them
  • Forced labour – work or service done involuntarily under threat of punishment
  • Debt bondage – being forced to work to repay a debt
  • Child labour – exploitation of children through any form of forced or illegal work
  • Servitude – being forced to live and work in degrading conditions without personal freedom

5. Our Responsibilities

At Infinics Limited, we:

  • Maintain and enforce an Anti-Slavery and Human Trafficking Policy
  • Assess risks of modern slavery in our business and supply chains
  • Conduct appropriate due diligence when onboarding new suppliers
  • Ensure all supplier contracts include anti-slavery clauses
  • Provide training to relevant employees
  • Encourage a culture of openness and reporting

6. Due Diligence & Risk Assessment

We carry out due diligence in the following areas:

  • Supplier assessments – ensuring suppliers meet our ethical standards
  • Contract reviews – requiring suppliers to declare compliance with modern slavery laws
  • Geographic and sector analysis – identifying high-risk areas in our supply chain

We prioritise due diligence on suppliers operating in sectors or countries known to have higher modern slavery risks.

7. Employee Conduct and Awareness

Employees are expected to:

  • Comply with this policy and all related laws
  • Report any suspicion of modern slavery immediately
  • Complete any training provided on identifying and preventing modern slavery

We provide periodic training to relevant staff on how to recognise signs of exploitation and how to report concerns.

8. Whistleblowing and Reporting Concerns

We encourage all employees, contractors, and third parties to report any suspicions or concerns about modern slavery. Reports can be made confidentially via:

📧 Email: info@infinics.co.uk
☎️ Phone: 0333 344 4043

Reports will be investigated promptly and treated with the utmost seriousness. No one will suffer retaliation for reporting concerns in good faith.

9. Compliance and Breaches

Any employee found to be in breach of this policy will face disciplinary action, up to and including termination of employment.

Infinics Limited may terminate relationships with suppliers or contractors who do not comply with our Anti-Slavery Policy or fail to provide evidence of compliance when requested.

10. Review and Updates

This policy is reviewed annually and updated where necessary to ensure it remains effective and relevant. The latest version will always be available on our internal systems and published on our website.

Approved by:
Kevin Brown
Chief Executive Officer
Infinics Limited
Date: 17th September 2019