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Anti - Slavery Policy

Policy Statement

This Policy sets out HFG’s zero-tolerance approach to modern slavery. HFG is committed to acting ethically and with integrity in all its business dealings and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of its supply chains.

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.

HFG are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other third parties. As part of our contracting processes, we expect that our suppliers will hold their own suppliers to the same standards set out in this policy..

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.


The board of Directors has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those staff and third parties under its control comply with it.

Who does this Policy Apply to?

This policy applies to all persons working for HFG or on our behalf in any capacity, including employees at all levels, Directors, officers, agency workers, volunteers, interns, agents, contractors, external consultants (“third parties”).

Scope and Purpose of the Policy

This policy describes how the HFG aims to prevent, detect and report modern slavery in any part of its business or supply chains.

HFG aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual should inform either a Director or the HR representative immediately. If the matter is not remedied, an employee should raise it formally in accordance with the HFG Grievance Procedure, which is published on the intranet.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify a Director or report it in accordance with our Whistleblowing Policy as soon as possible.

Compliance with the policy

All staff and third parties must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy.

If any third party believes or suspects a breach of this policy has occurred or that it may occur they must notify a senior HFG point of contact as soon as possible.

Directors are responsible for ensuring that this policy and HFG’s zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with this policy and are given adequate training as applicable on the policy and the issue of modern slavery.

The HR representative have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

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.

Investigations & Disciplinary Action

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

HFG may terminate its relationship with other third parties if they breach this policy.