1.Policy Statement
Hatch is committed to acting ethically and with integrity in all our business dealings and relationships. We have a zero-tolerance approach to modern slavery, and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including 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. We are committed to acting ethically and with integrity in all our business relationships, and to implementing effective systems to ensure that modern slavery is not taking place anywhere within our business or supply chains.
2.Purpose and Scope
This policy sets out Hatch’s approach to identifying and preventing modern slavery and human trafficking in our operations and supply chains. It applies to all persons working for us or on our behalf, including employees at all levels, directors, officers, agency workers, seasonal workers, contractors, consultants, and business partners
3. Our Commitments
We commit to:
• Maintain a zero-tolerance approach to modern slavery and human trafficking in our business and supply chains.
• Conduct due diligence on suppliers, contractors, and other business partners before entering commercial relationships.
• Assess and monitor potential risk areas within our business and supply chains on an ongoing basis.
• Provide adequate protection for whistleblowers who raise concerns in good faith.
• Provide training to relevant staff on how to identify and respond to the risks of modern slavery.
• Take appropriate action where instances of modern slavery are identified, including working with suppliers to remediate issues or ending the relationship where necessary.
4. Responsibility for This Policy
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. Jason Madeley, Managing Partner has primary responsibility for implementing this policy, monitoring its effectiveness, and ensuring it is reviewed annually.
Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy, and for identifying and mitigating risk in their areas of responsibility.
5. Supply Chain Due Diligence
As part of our efforts to monitor and eliminate the risk of modern slavery in our supply chains, we may:
• Map and assess suppliers to identify those operating in higher-risk sectors or geographies.
• Include anti-slavery and human trafficking provisions in supplier agreements.
• Require suppliers to maintain records enabling us to trace the supply chain of all goods and services.
• Reserve the right to inspect suppliers’ premises and records, and to meet their personal, in order to audit their compliance with anti-slavery and human trafficking obligations.
• Require suppliers to notify us as soon as they become aware of any actual or suspected breach of anti-slavery and human trafficking laws or obligations.
• Require suppliers to confirm that they have not been convicted of any offence involving slavery or human trafficking, nor are subject to any investigation, inquiry, or enforcement proceedings in connection with any such offence.
6. Recruitment and Employment Practices
Hatch operates robust recruitment practices, including verifying the right to work of all workers and never charging recruitment fees to candidates. We ensure workers are free to leave employment after reasonable notice, are paid at least the minimum wage applicable in their jurisdiction and are not required to surrender identity documents or pay deposits as a condition of employment.
7. Training and Awareness
We provide training to employees, particularly those in procurement, human resources, and other roles with supply chain or hiring responsibilities, to help them recognise the signs of modern slavery and understand the steps to take if they have concerns. We keep a record of training provided and completed.
