Introduction

Momentum Instore operates a zero-tolerance approach to Modern Slavery and we are dedicated to ensuring it has no place in our business or supply chain. Modern Slavery is a crime as well as a fundamental breach of human rights and may present in different ways such as slavery, servitude, forced and compulsory labour and human trafficking. This policy applies to all who work or provide services for Momentum Instore in any capacity, including (but not limited to) Directors, employees at all levels, temporary workers, volunteers, interns, sub-contractors, and suppliers.

Responsibility for the Policy

The Board of Directors maintain overall responsibility for compliance with legal responsibility in relation to the Policy and ensuring that all those under its control are compliant. The Head of Talent and Engagement maintains primary responsibility for implementing this Policy and monitoring its use and effectiveness. Day to day responsibility for queries relating to this Policy is delegated to the Senior HR Advisor. Managers should ensure that those who report into them are given adequate and regular training on it and the issue of Modern Slavery in supply chains.

Compliance

As an individual, you must ensure that you read, understand, and agree to comply with this Policy. The prevention, detection, and reporting of Modern Slavery in any part of our business or supply chain is the responsibility of all those who work for Momentum Instore or under our control. You must avoid any activity that may lead to or suggest a breach of this policy. If you suspect a breach of this Policy has occurred or may occur, or you are unsure whether a particular situation within the supply chain constitutes any form of Modern Slavery you should raise it with your Line Manager or the Talent and Engagement team as a matter of urgency.

Other Policies

There are several other policies to ensure our business is conducted in an ethical and open manner. These include:

1. Equal Opportunity Policy. This policy covers robust recruitment practices to safeguard against any form of Modern Slavery of Human Trafficking.
2. Whistle-blowing Policy. Our policy ensure that all employees understand how they can raise concerns about practices within our business or supply chain without fear of reprisal.
3. Business Partner Agreements. The agreements with key business partners clearly set out our expectations in relation to Business Practice, Employment, Business Ethics and Health, Safety, and Wellbeing.

Training

Momentum Instore are dedicated to raising awareness of Modern Slavery by providing online training to all employees. This is a demonstration of the commitment to legal requirements under Section 54 of the Modern Slavery Act 2015. As part of a robust induction process, all new starters are required to complete online training in Modern Slavery, this will be refreshed annually for all staff.

Breaches of this Policy

As stated in the introduction, Momentum Instore maintains a zero-tolerance approach to Modern Slavery, as a result any breaches of this policy may be treated as Gross Misconduct and may result in dismissal without notice. For individuals, organisations and suppliers working on our behalf, a breach may result in the termination of our relationship. Date of Next Review: June 2023 REV – 00 DATE – April 2022 DESCRIPTION OF AMENDMENT – Original Issue AUTHORISED BY – H Chriscoli