Modern Slavery

ADAPT GSE – Modern Slavery Policy

1. Introduction
   • ADAPT GSE is committed to preventing all forms of modern slavery, human trafficking, and forced labour within its operations and supply chain. As an engineering company, we recognise our responsibility to promote ethical practices and respect human rights, ensuring that modern slavery has no place in our business or the industry in which we operate.

2. Purpose of the Policy
   • This policy sets out ADAPT GSE’s approach to identifying, preventing, and addressing risks of modern slavery and human trafficking. It outlines our commitment to act with integrity, transparency, and accountability in all business activities and to uphold the highest standards of ethical conduct.

3. Scope
   • This policy applies to all employees, contractors, suppliers, and any other business partners of ADAPT GSE. It is the responsibility of everyone within our company to ensure compliance with this policy and to actively work towards eradicating modern slavery.

4. Our Commitments
   • ADAPT GSE commits to:
     • Compliance with Laws and Regulations: Adhere to the Modern Slavery Act 2015 and all relevant international laws aimed at eradicating modern slavery and human trafficking.
     • Due Diligence: Conduct regular due diligence on our supply chain, contractors, and business partners to identify, assess, and mitigate potential risks of modern slavery.
     • Supplier and Partner Vetting: Require all new and existing suppliers to comply with our modern slavery standards. This includes implementing robust measures to ensure their business practices are free from slavery, human trafficking, and forced labour.
     • Training and Awareness: Provide regular training to all employees on identifying the signs of modern slavery and how to report concerns. We also aim to raise awareness among suppliers and business partners regarding the importance of combatting modern slavery.
     • Zero Tolerance: Maintain a zero-tolerance approach towards modern slavery within our operations. Any breach of this policy by employees, suppliers, or contractors will result in appropriate disciplinary action, including potential termination of contracts or partnerships.

5. Supply Chain Responsibility
   • As an engineering company, we recognise the complexity of our supply chain and the potential risks associated with it. We are committed to ensuring that:
     • Our suppliers and contractors comply with the principles of ethical sourcing.
     • Suppliers undergo a thorough assessment, including ethical audits and regular monitoring, to ensure their compliance with this policy.
     • We engage only with suppliers who share our commitment to eradicating modern slavery and implement appropriate remediation measures where necessary.

6. Reporting Concerns
   • ADAPT GSE encourages a culture of openness and transparency. All employees, suppliers, contractors, and business partners are expected to report any suspicions or evidence of modern slavery in our business or supply chain.
   • Whistleblowing: Employees and external stakeholders can report concerns confidentially via our whistleblowing procedures. Reports can be made anonymously, and all concerns will be treated seriously and investigated thoroughly.
   • Protection Against Retaliation: We are committed to protecting whistleblowers from any form of retaliation or victimisation for reporting concerns in good faith.

7. Monitoring and Review
   • This policy will be reviewed annually by ADAPT GSE’s senior management team to ensure its ongoing relevance, effectiveness, and compliance with legal obligations. We will also monitor our supply chain and internal operations regularly to assess risks and implement any necessary improvements.

8. Responsibility for the Policy
   • The ultimate responsibility for the implementation and enforcement of this policy lies with the senior management team of ADAPT GSE. However, every employee and partner of ADAPT GSE shares the responsibility for upholding these principles.

9. Policy Updates
   • This Modern Slavery Policy may be updated periodically to reflect any changes in legislation, business practices, or our approach to combatting modern slavery.

ADAPT GSE is committed to fostering a business environment free from the practices of modern slavery. By working together, we can ensure that dignity and respect are at the forefront of all our operations and that we play our part in the global effort to end modern slavery.