Speculo Limited is committed to preventing and addressing modern slavery in all its forms. It recognises that modern slavery is a global issue that affects millions of people worldwide and is dedicated to playing its part in eradicating it. This Modern Slavery Policy outlines Speculo’s commitment, principles, and actions to ensure that modern slavery does not exist within its organisation or our supply chains.
1 Policy Statement
1.1 Commitment
Speculo Limited is committed to the principles of freedom, dignity, and human rights for all individuals. It condemns all forms of modern slavery, including forced labour, human trafficking, debt bondage, and any other exploitative practices.
1.2 Scope
This policy applies to all employees, contractors, suppliers, and stakeholders involved in Speculo Limited’s operations.
1.3 Compliance
It will comply with the Modern Slavery Act 2015 and all other applicable laws and regulations related to modern slavery.
2 Prevention of Modern Slavery
2.1 Supply Chain Due Diligence
Speculo Limited will undertake due diligence measures to identify and assess the risk of modern slavery in its supply chains.
2.2 Supplier Code of Conduct
It will implement a robust Supplier Code of Conduct that explicitly prohibits modern slavery and sets out its expectations for ethical conduct. It will require its suppliers to acknowledge and adhere to this code as a condition of doing business with Speculo Limited.
2.3 Employee awareness and training
It will provide training and awareness programmes to its employees to ensure they understand modern slavery risks, indicators, and reporting mechanisms. It will empower its employees to report any suspicions or concerns related to modern slavery.
3 Reporting and whistleblowing
3.1. Reporting mechanisms
Speculo Limited encourages the reporting of any concerns, suspicions, or incidents of modern slavery. It has established clear reporting channels, which allow individuals to report anonymously if they wish. It will treat all reports confidentially and investigate them promptly and thoroughly.
3.2 Non-retaliation
It is committed to protecting individuals who report in good faith. It will not tolerate any form of retaliation against those who raise concerns about modern slavery.
4 Monitoring and review
4.1 Monitoring
Speculo Limited will regularly monitor and assess its compliance with this Modern Slavery Policy and its ongoing efforts to combat modern slavery.
4.2 Review
It will review and update this policy periodically to ensure its effectiveness and alignment with best practices.
5 Communication and engagement
5.1 Communication
Speculo Limited will communicate this Modern Slavery Policy internally and externally to raise awareness and demonstrate its commitment to combating modern slavery.
5.2 Stakeholder engagement
It will engage with relevant stakeholders, including suppliers, industry partners, and civil society organisations, to collaborate and share best practices in addressing modern slavery.
6 Responsibilities
6.1 Board and senior leadership
The Board and senior leadership team are responsible for overseeing the implementation of this policy, ensuring adequate resources, and setting the Company’s direction in combating modern slavery.
6.2 Employees
All employees have a responsibility to familiarise themselves with this policy, adhere to its principles, and report any concerns related to modern slavery.
7 Review and approval
This Modern Slavery Policy has been approved by Speculo Limited’s senior leadership and is effective from 1 June 2023. It will be regularly reviewed and updated as necessary.
By implementing this Modern Slavery Policy, Speculo Limited affirms its commitment to combating modern slavery.