Anti-Slavery and Human Trafficking Policy

Sandhill Consultants Limited understand that modern slavery and human trafficking is a crime that violates an individual’s fundamental human rights, depriving a person’s liberty in order to exploit them for personal or commercial gain. Sandhill act with integrity and in an ethical manner in all of our business relationships and activities, ensuring modern slavery and human trafficking has no place in our own business, or in our supply chain.

Sandhill are committed to ensuring that we meet any and all of our obligations under the Modern Slavery Act 2015. We expect similar high standards to be maintained by our partners, suppliers and any subcontractors that we engage to work on our behalf.

Whilst National Referral Mechanism statistics show a year-on-year increase in the number of referrals of potential victims of modern slavery, the risk of slavery and human trafficking remains relatively low in the United Kingdom. Sandhill acknowledges that these figures represent only a proportion of cases of exploitation and therefore remains vigilant and committed to preventing and taking action against identified slavery and human trafficking in its business activities, its supply chains and any interactions with organisations based outside of the UK.

This policy applies to all persons working for Sandhill or on our behalf, in any capacity, including all employees, directors, subcontractors, external consultants and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.


Responsibility for the policy


Sandhill Consultants Limited’s directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all our people adhere to it.

Day-to-day responsibility for policy implementation, staff awareness and ongoing risk assessment lies with the relevant business area where there is deemed to be a risk of modern slavery or human trafficking. This responsibility includes reviewing the risk profile of any new suppliers or external resources contracted to undertake work on Sandhill’s behalf. Risk assessments will be signed off by a Company director.


Compliance with the policy


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 chain 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. Any concerns regarding modern slavery and human trafficking in our business or supply chain should be reported immediately to a business manager or director. Specific queries regarding this policy or relevant legislation can be discussed with members of the Sandhill Management Team.

Sandhill encourage openness and ask that you err on the side of caution, without fear of retaliation, where there might be a contravention of any aspect of this policy. Concerns raised in good faith, whether they turn out to be legitimate or mistaken, will be fully supported by the Management Team and kept in confidence where necessary.


Communication and awareness of this policy


Sandhill makes clear to all staff its zero-tolerance approach to modern slavery and human trafficking from their point of first employment, ensuring ongoing training is provided where necessary.
Our requirements under this policy are communicated to all significant partners, suppliers and contractors at the outset of any business relationship and are then reinforced as appropriate.


Breaches of this policy


Where a Sandhill employee is found to have breached this policy, this may lead to disciplinary action and could result in dismissal for misconduct or gross misconduct. Should an individual or organisation working on behalf of Sandhill breach the policy, then we may terminate the business relationship.