Anti-slavery & anti-human trafficking policy

Modern slavery encompasses slavery, forced and compulsory labor, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain.

Transform is committed to combating slavery and human trafficking and to acting with integrity in all its dealings, relationships, supply and sales chains.  It expects the same high standards from all its staff, suppliers, contractors, clients and those with whom it does business.  This policy applies to all employees, workers, consultants, and other persons doing business with Transform including all its wholly owned group subsidiaries and branches, contractors, and suppliers.

Transform acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labor.  Although Transform considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

  • The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for Transform or under its control
  • Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s)
  • All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.  Our standard contract addresses anti-slavery and anti-trafficking.  Staff working in Resourcing are trained in the importance of these provisions.
  • Transform encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith
  • Transform’s search and selection policies and procedures support its efforts to combat modern slavery and human trafficking
  • Transform will continue to develop its commitment to combat modern slavery and human trafficking and will outline such activities within its annual anti-slavery and anti-trafficking statement.

Any breaches of this policy may result in Transform taking disciplinary action against individual(s) and/or terminating its relationship with any supplier or client.