Purpose
This policy outlines S Jones Containers commitment to preventing modern slavery and human trafficking in all forms across our business operations and supply chains. We are dedicated to acting ethically, with integrity, and to implementing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our organisation or those we do business with.
Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking. These practices deprive individuals of their freedom and exploits them for personal or commercial gain.
S Jones Containers has a zero-tolerance approach to modern slavery. We are committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all 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, and against anyone held in slavery or servitude. We also expect our suppliers to hold their suppliers to the same high standards.
This policy applies to all individuals working for or on behalf of the company in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, contractors, external consultants, third-party representatives, and business partners.
Risk Assessment and Due Diligence
We assess the risk of modern slavery in our business and supply chains, particularly in relation to:
- High-risk geographical areas;
- Industries or activities with a higher prevalence of exploitative labour;
- Suppliers with low visibility or limited disclosure.
To mitigate these risks, we:
- Carry out supplier due diligence checks;
- Include anti-slavery obligations in contracts with suppliers;
- Where appropriate, request supplier self-assessments or certifications;
- Monitor supplier performance and compliance periodically.
Roles and Responsibilities
Senior Management is responsible for ensuring compliance with this policy and for implementing appropriate systems and controls.
Line Managers are responsible for ensuring their teams understand and comply with this policy and are alert to the risks of modern slavery.
Employees and Contractors are expected to remain vigilant and report any suspicions of slavery or human trafficking in any part of our business or supply chain.
Compliance and Reporting
The prevention, detection, and reporting of modern slavery is the responsibility of everyone working for us or on our behalf.
Employees must:
- Avoid any activity that could lead to a breach of this policy;
- Report any concerns as soon as possible to their line manager or via the Whistleblowing Policy;
- Raise concerns even if they are uncertain whether a particular situation constitutes modern slavery.
All concerns will be taken seriously and investigated promptly. Reports made in good faith will not result in any victimisation or retaliation, even if they turn out to be mistaken.
Training and Awareness
We provide training to relevant staff on this policy and the risks of modern slavery, particularly to those involved in procurement, recruitment, or supplier management. This training ensures they can identify risks and respond appropriately.
Our zero-tolerance approach is also communicated to all suppliers, contractors, and business partners at the outset of our relationship and reiterated as appropriate.
Monitoring and Continuous Improvement
We will regularly review and update this policy to ensure its effectiveness. Updates may follow legislative changes, business growth, or evolving supply chain risks.
Audits or spot checks may be carried out from time to time to assess supplier compliance.
Modern Slavery Statement
Although we are currently below the £36 million turnover threshold requiring an annual Modern Slavery Statement under the Modern Slavery Act 2015, we remain committed to voluntarily disclosing our efforts where appropriate and as our business evolves.
Breaches of this Policy
Any employee who breaches this policy may face disciplinary action, up to and including dismissal.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy or fail to provide adequate assurances.
Further Information
Further reading on the Modern Slavery Act 2015 can be found at: https://www.legislation.gov.uk
Policy reviewed: 18.06.2025
