1. Policy Statement
This policy applies to Elemental Concept’s entities globally and is designed to meet the requirements of applicable legislation in each jurisdiction where we operate. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, contractors and suppliers.
Elemental Concept strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
This policy is reviewed annually and is implemented in accordance with the Modern Slavery Act 2015.
2. Commitments
2.1 Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour, forced marriage, domestic servitude and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
- We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
2.2 Ethical Recruitment
- Elemental Concept is committed to ethical recruitment practices. We will never charge workers recruitment fees, and we will never withhold, retain or otherwise control any worker’s identity documents or personal possessions.
- We will only engage recruitment agencies that can demonstrate compliance with ethical recruitment standards consistent with this policy.
2.3 Reporting Concerns
All workers have a responsibility to be alert to the signs of modern slavery and to report any concerns promptly.
How to report a concern:
- Speak directly to your line manager or HR representative; or
- Use Elemental Concept’s confidential whistleblowing/speak-up process as set out in our Whistleblowing Policy.
| Jurisduction | Resource | Contact |
|---|---|---|
| United Kingdom | Modern Slavery Helpline | 0800 0121 700 |
| United Kingdom | National Crime Agency | www.nationalcrimeagency.gov.uk |
| Australia | Australian Federal Police | 131 237 |
| Australia | Anti-Slavery Commissioner | www.antislaverycommissioner.gov.au |
| New Zealand | Police (non-emergency) | 105 |
| New Zealand | Human Rights Commission | 0800 496 877 |
| Singapore | National Anti-Human Trafficking Hotline | 1800 777 0000 |
| India | Anti-Human Trafficking Helpline | 181 (Women Helpline) / local Anti-Human Trafficking Units |
| Germany | Federal Police (Bundespolizei) | +49 800 6 888 000 |
We are committed to ensuring that anyone who raises a concern in good faith will not suffer any detriment or disadvantage as a result of doing so.
3. Review
This policy will be reviewed annually by HR, or sooner in the event of legislative changes, significant business change, or following any identified breach. Any material amendments will be approved by the Board and communicated to all staff.
For questions about this policy, please contact hr@elementalconcept.com.
This policy is last updated on 22 April 2025 and replace all other policies previously applicable.