Modern Slavery Policy

ESTS (GB) Ltd is determined to achieve the highest standards of ethical trading throughout its extended supply chain and  is committed to working with all relevant bodies to deliver effective action plans for change. We believe that, by working together with all our suppliers, we can strengthen our business and improve the quality of life of the people whom we touch.

The policy exists for the purposes of promoting safe and fair working conditions and the responsible management to prevent or identify issues related to modern slavery in ESTS (GB) Ltd.

Responsibility

The Managing Director has operational responsibility for the implementation of the Policy.

An MSAT risk assessment has been conducted and identified our operation to be 'Low Risk'. 

Nevertheless, the company will remain vigilant and conscious of change and communicate and promote its Modern Slavery Policy internally and externally to relevant stakeholders.

Supply Chain - Communication

Suppliers are required to promote the policy to their own staff and to their subcontractors.

The company and its suppliers will take steps to ensure that relevant people are provided with appropriate training and guidelines to support the communication of the policy and will work collaboratively, where possible, with its suppliers on the implementation of the policy, which may include site visits to assess performance against the policy where risk has been identified.

Standards of Conduct

Through this policy the company shall ensure that:

There is no forced, bonded or involuntary prison labour. Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.

Freedom of association and the right to collective bargaining are respected. Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

Worker’s representatives are not discriminated against and have access to carry out their representative functions in the workplace.

Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Workers shall receive recorded health and safety training, and such training shall be repeated for new or reassigned workers.

Access to clean toilet facilities and to potable (drinking) water, and, if appropriate, sanitary facilities for food storage shall be provided.

The company observing the code shall assign responsibility for health and safety to a senior management representative.

There shall be no child labour.

Young persons under 18 shall not be employed at night or in hazardous conditions.

We will always conform to the relevant local regulations and recognised ILO standards.

Living Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned.

Working hours are not excessive. Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.

In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off.

There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.

Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

No harsh or inhumane treatment is allowed - Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Suppliers will have a formal disciplinary and grievance appeal procedure with documented records of individual disciplinary hearings. Such a procedure will support fair treatment of workers.

Reporting

We will report on the performance of the company in this regard via annual report.

Suppliers are expected to identify and correct any activities that conflict with the standard of the policy via verifiable continual improvement programmes agreed by the Managing Director.

Suppliers shall immediately report any serious breaches of the policy, together with a schedule for corrective action agreed.

Where serious breaches of the policy persist, the company will consider termination of the business relationship with the supplier concerned.

David Hawtin
Managing Director
ESTS (GB) Ltd

Issued - October 2023
Reviewed - November 2024
Next Review - November 2025