Scope

This policy applies to all employees, agency staff, contractors, consultants or any person working on behalf of Exception, and our clients and suppliers.

All employees are expected to be aware of and comply with this policy and are responsible for meeting these commitments and for raising any concerns or ideas for improvement.

Managers are responsible for applying the policy and ensuring that any issues are dealt with swiftly.

Policy in Practice

Fair Labour Statement

Exception has an inclusive environment that is based on the selection and retention of employees on the basis of individual ability and achievement, where anyone has the opportunity to develop their full potential. This positive approach to promoting diversity is a key element of its strategy for success as an inclusive employer, and a service provider of choice.

At Exception we understand the importance of our most valuable assets – our employees, clients and suppliers and we work towards ensuring that equality of opportunity is embedded within our policies, practices and procedures.

We are also committed to the principles of equality of opportunity in employment and customer experience. We endeavour to ensure that no employee, customer, contractor and/or visitor suffer any discrimination, nor are they disadvantaged due to age, colour, disability, ethnic or national origin, marital status, nationality, race, religion, sex, sexual orientation, or other considerations not justified in law which are irrelevant to the performance of the job.

Worker Representation

All workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. We adopt an open attitude towards the activities of trade unions and their organisational activities and workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

Human Trafficking & Modern Slavery Statement

At Exception we conduct our business with integrity, transparency and fairness. We are committed to the prevention of slavery and human trafficking both in our business and in our supply chains. We procure goods and services in a sustainable and ethical manner in compliance with our values and relevant law and policy, including the Modern Slavery Act 2015.
We do not accept slavery or human trafficking in our business and we will not work with others who do not share our commitment to preventing slavery and human trafficking.

Due diligence in our supply chains

We have reviewed and will continue to review our supplier list and conduct risk assessments of our supply chains. This supports our commitment as far as is possible, to ensure that slavery and human trafficking is not occurring in any part of our supply chain.

Training

All members of staff are required to certify that they have read and understood this Policy.

Key Performance Indicators

We use the following Key Performance Indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• All staff have confirmed that they have read and understood this Policy
• Any policy breaches are reported within a reasonable time of occurring
• Any policy breaches are assessed within a reasonable time of being reported and further investigations concluded as soon as possible thereafter

We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any instances of slavery and human trafficking. We understand that an Anti-slavery Policy is not sufficient to prevent slavery and human trafficking. It is important to develop a culture within the firm which does not tolerate slavery or human trafficking and is not complacent about the associated risks. Through our good business practices and HR policies, including our adoption of the Scottish Business Pledge, we believe that we have established such a culture, including compliance with national working hours legislation, and not exceeding ILO standards. Exception is committed to positively fostering this culture across the company through training, education and awareness initiatives.