Created: 08/2015
Latest Review/Update: 08/2016
Version: 1

Overview

The MBA Group Ltd Statement on Slavery and Human Trafficking establishes MBA’s commitment to preventing the use of forced, bonded, indentured labour, involuntary prison labour, slavery or trafficking of people. The Policy embodies the spirit of our Corporate Social Responsibility Policy, Human Rights Policy and Business Conduct & Ethics Code.

This Policy applies to all employees. MBA Group Ltd also expects our suppliers to maintain progressive employment, environmental, health and safety practices that meet or exceed all applicable laws and relevant codes of practice such as MBA’s Business Conduct & Ethics Code.

MBA Group Ltd is committed to respecting human rights and upholding the values and high standards of ethics expressed in our Human Rights Policy, Corporate Social Responsibility Policy and Business Conduct & Ethics Code.

MBA Group Ltd Statement on Slavery & Human Trafficking

MBA Group Ltd will not use or tolerate the use of forced, debt bonded, indentured labour, involuntary prison labour, slavery or human trafficking in its business or supply chain. This includes recruiting, harbouring, transporting, providing, receiving, or obtaining of a person for labour services, or commercial sex acts through the use of force, fraud, coercion, abduction or fraud for the purpose of involuntary servitude, peonage, debt bondage, or slavery.

There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. All work must be voluntary.

We will not destroy, conceal, hold or otherwise deny access by employees to their identity or immigration documents, such as passports, work permits or drivers’ licenses regardless of issuing authority. The one exception is where the holding of a work permit by the employer is required by law.

Migrant workers shall not pay for their employment. Any recruiters used to source workers must comply with UK Law. The costs of recruiting and hiring, transportation (to facility and return home), or any government imposed fees shall be paid directly by the supplier. Any fees charged to the workers must be disclosed and returned to them.

Workers shall not be required to post any bond or make any deposit. The worker shall not be required to participate in any savings program unless required by law. Working conditions, pay, benefits and treatment of migrant workers must be the same as local workers. Worker dormitories contracted or provided by the supplier or a labour agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space.

MBA Group Ltd has management systems in place to monitor and track our compliance, as well as our suppliers with all of these expectations on human trafficking and slavery.

We expect our suppliers to respect human rights, including maintaining policies and procedures to prevent the use of child or forced labour. We conduct ongoing due diligence of key suppliers to ensure compliance with Section 54 of the Modern Slavery Act 2015.

Our suppliers are contractually obligated to fully comply with MBA’s Business Conduct & Ethics Code and all applicable laws. We have internal accountability standards and procedures for employees and contractors who fail to meet our expectations regarding MBA’s Business Conduct & Ethics Code. We provide induction training and access to all applicable information for our employees.

MBA Group Ltd maintains management systems to report non-compliance of potential ethical, legal or regulatory violations related to our suppliers.