Our Anti-Slavery and Human Trafficking Policy

1. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Company Commitment: Focus Banners

Focus Banners has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Scope of This Policy

This policy applies to all persons working for us or on our behalf in any capacity, including:

  • Employees at all levels (directors, officers, senior managers, permanent, casual, and temporary staff)

  • External consultants and contractors

  • Agency workers and volunteers

  • Suppliers, vendors, and third-party business partners

3. Responsibilty For the Policy

Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy, and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4. Due Diligence and Supply Chain Compliance

We expect the same high standards from all of our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude.

To identify and mitigate risk, we commit to:

  • Vetting and auditing our suppliers and supply chains to ensure compliance with this policy.

  • Requiring our suppliers to complete annual modern slavery self-assessment questionnaires (where applicable).

  • Terminating relationships with suppliers or partners that fail to improve their practices or show flagrant disregard for human rights.

5. Employee Responsibilities and Reporting

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us.

  • Be Vigilant: Employees must avoid any activity that might lead to, or suggest, a breach of this policy.

  • Speak Up: If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, you must notify your manager or report it in accordance with our Whistleblower Policy as soon as possible.

Safe Reporting Protection

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Focus Banners is committed to ensuring no one suffers any detrimental treatment or retaliation as a result of reporting their suspicion.

6. Training and Communication

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established internal communication channels.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

7. Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which may result in termination of employment for serious misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.