modern slavery Policy

Modern slavery is an egregious abuse of basic human rights, manifesting in forms like forced labor, human trafficking, and servitude. These practices strip individuals of their freedom, exploiting them for personal or commercial gain. At TAG Traders, we stand firmly against all forms of modern slavery. Our commitment to ethical conduct and integrity is unwavering, and we rigorously implement robust systems and controls to prevent any occurrence of modern slavery within our operations and supply chains. We are dedicated to fostering a business environment where human dignity is respected and upheld at all times.

We are dedicated to maintaining transparency within our business and our efforts to combat modern slavery across our supply chains, in line with the Modern Slavery Act 2015. We uphold high standards for our contractors, suppliers, and business partners, incorporating explicit prohibitions against forced, compulsory, or trafficked labor, as well as any form of slavery or servitude, in our contracting processes. We expect our suppliers to enforce these same standards with their own supply chains.

This policy is applicable to everyone working for or on behalf of our company, including employees at all levels, directors, officers, agency workers, seconded staff, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Please note, this policy is not part of any employee's contract and may be amended at our discretion.

The Director holds the ultimate responsibility for ensuring our Policy aligns with both legal and ethical standards and for ensuring compliance among all individuals under our control. The Director is tasked with the primary and day-to-day responsibilities of enforcing this Policy. This includes monitoring its application and effectiveness, addressing any related questions, and auditing our internal systems and procedures to prevent modern slavery. Managers at all levels must ensure their team members understand and adhere to this Policy. They are also responsible for providing sufficient and ongoing training on the Policy and the issue of modern slavery in supply chains.

To maintain compliance with our policies, it is essential that you thoroughly read, comprehend, and adhere to this Policy.

Every individual associated with our organisation, whether directly employed or within our supply chains, shares the responsibility for preventing, detecting, and reporting instances of modern slavery. It is mandatory to abstain from any actions that may hint at or lead to a violation of this Policy.

If you: 

• Have reason to suspect or believe that a breach of this Policy has occurred or may occur in the future; 

• Wish to express concerns regarding potential instances of modern slavery within any aspect of our business operations or across our supply chains at any tier;

You are encouraged to promptly raise these concerns with your manager or directly with the Director. Alternatively, you may report such issues in accordance with our Whistleblowing Policy. Even if uncertain about the nature of a particular activity or the treatment of workers within our supply chains, we urge you to voice your concerns. Our aim is to foster an environment of transparency, and we pledge to support any individual who reports genuine concerns in good faith under this Policy, irrespective of the eventual outcome. Our commitment extends to ensuring that no individual faces any form of adverse treatment as a consequence of raising concerns in good faith regarding suspected modern slavery within our business or supply chains. 

Adverse treatment includes dismissal, disciplinary action, threats, or any other form of unfavourable treatment linked to the act of reporting concerns. Should you believe that you have encountered such treatment, we encourage you to immediately inform your manager or the Director, or follow the reporting procedures outlined in our Whistleblowing Policy. Should the matter remain unresolved, employees are advised to utilize our formal Grievance Procedure for further recourse.

Our tailored policy is meticulously designed to address the unique risks inherent in the sector of operation for Chameleon Business Interiors. Recognising the intricacies of our supply chains and the diverse geographic locations of our suppliers, we have identified 

several key areas of concern:

• Engagement with consultants, contractors, and suppliers across various stages of the construction cycle. 

• Utilisation of materials such as 'conflict minerals' and steel sourced from regions with poor records on slavery and trafficking.

To mitigate these risks and uphold our commitment to combatting modern slavery and human trafficking, we have implemented comprehensive measures, including:

• Requesting confirmation of adherence to our Anti-Slavery Policy from existing and potential sub-contractors, consultants, and advisers. 

• Incorporating anti-slavery provisions into contractual agreements and conducting due diligence through questionnaires. 

• Regular review of high-risk areas to identify and address potential vulnerabilities within our supply chain.

• Establishment of a robust whistleblowing procedure to encourage reporting of any breaches of our Anti-Slavery Policy.

Furthermore, in 2018, we bolstered our efforts with additional initiatives:

• Inclusion of modern slavery and human trafficking risk on company risk registers, subject to biannual review. 

• Development of supplier briefing packs and site information materials to raise awareness and facilitate reporting.

• Outreach to existing suppliers, consultants, and professional advisers to reaffirm adherence to our Anti-Slavery Policy. 

• Enhancement of supplier audit capabilities to address potential issues related to human trafficking or slavery.

• Mandating suppliers and sub-contractors to implement their own due diligence practices and whistleblowing procedures, in alignment with our Policy and legal requirements.

Through these proactive measures, we are steadfast in our commitment to eradicating modern slavery and human trafficking from our supply chains and fostering a culture of ethical business conduct.

All individuals joining our team undergo thorough induction training, which includes education on this Policy and the risks associated with modern slavery in our supply chains. Ongoing training will be provided as needed to ensure awareness and compliance.

From the onset of our business relationships, we communicate our zero-tolerance stance on modern slavery to all suppliers, contractors, and partners. This commitment is reiterated as needed throughout our engagements.

Employees found to be in violation of this policy will be subject to disciplinary measures, potentially leading to dismissal for misconduct or gross misconduct. Similarly, any individuals or organisations collaborating with us who contravene this policy may face termination of their relationship with us.

We regularly review and update our Anti-Slavery Policy to ensure its effectiveness and compliance with evolving requirements.

For and on behalf of TAG Traders Ltd

2024