Hives Lodges

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Modern Slavery Act

Modern Slavery Act

Our organisation is firmly dedicated to maintaining the highest standards in our interactions with employees, customers, and suppliers. We prioritise inclusivity, honesty, integrity, and transparency in all our business operations. This commitment is reflected in our adherence to the Modern Slavery Act, which outlines our determination to combat modern slavery.

Introduction
  1. Hives Lodges is fully committed to upholding an effective anti-slavery and anti-human trafficking policy. We have established procedures to ensure compliance with the Modern Slavery Act 2015.
  2. Modern slavery is a criminal offense that violates fundamental human rights and takes on various forms, such as slavery, servitude, forced labour, and human trafficking. These acts involve the exploitation of individuals by depriving them of their freedom for personal or commercial gain. Hives Lodges adopts a zero-tolerance approach to modern slavery, striving to act ethically and responsibly in all business dealings, while implementing robust measures to prevent such practices in our operations and supply chains.
  3. Transparency is crucial in Hives Lodges efforts to tackle modern slavery across our supply chains. In line with the disclosure obligations of the Modern Slavery Act 2015, we expect our contractors, suppliers, and business partners to uphold the same standards. Our agreements include strict prohibitions against any use of forced labour or human trafficking, whether it involves adults or children, and we hold our suppliers accountable for meeting these standards with their own supply chains.
Scope
  1. The objectives of this policy are to:
    • Define the responsibilities of our organisation and those working on our behalf in adhering to our principles regarding modern slavery and human trafficking.
    • Provide guidance on recognising and reporting concerns related to modern slavery and human trafficking.
  2. This policy applies to everyone associated with Hives Lodges, including directors, employees, contractors, staff, interns, volunteers, consultants, and any third-party suppliers and partners.
  3. Our commitment to compliance extends to UK laws, particularly the Modern Slavery Act 2015. We recognise that slavery and human trafficking are criminal acts that infringe on basic human rights. This policy addresses these offenses, including any exploitation of individuals for personal or business gain.
  4. These offenses have a global reach, as they apply to acts committed anywhere in the world, not just within the UK.
  5. Individuals found guilty of slavery or human trafficking offenses face severe penalties, including life imprisonment.
  6. This policy does not form part of an employment contract and may be updated or revised as necessary.
Risk Assessment
  1. Regularly assessing the risk of slavery and human trafficking within each business unit is vital. Special attention will be directed toward markets where there is a high prevalence of modern slavery and insufficient anti-slavery laws.
  2. Our Internal Audit, and Risk departments will support these risk assessments and review each unit’s compliance with this policy as part of their ongoing audit process.
  3. Ongoing evaluations will take place every three years to reassess risks associated with our existing suppliers.
  4. Understanding and aligning with our Whistleblowing policy is essential when implementing this policy.
Due Diligence
  1. Hives Lodges will conduct in-depth due diligence on high-risk suppliers to ensure compliance with anti-slavery standards.
  2. For joint ventures or consortia, this policy applies to entities under our control. Where control is lacking, we encourage our partners to adopt similar standards.
  3. Any potential acquisitions will undergo thorough due diligence, focusing on the practices of the target company’s leadership and operations to ensure they are free from modern slavery.
  4. Additional scrutiny will be applied when dealing with companies in regions where slavery or trafficking is widespread.
Training and Communication
  1. Training on modern slavery risks and this policy is part of our onboarding process for new employees, with ongoing training provided as needed.
  2. We emphasize our zero-tolerance approach to modern slavery to all business partners at the start of any relationship and as necessary throughout our partnership.
Compliance with this Policy
  1. All staff must familiarise themselves with this policy and ensure they adhere to its principles.
  2. Preventing, detecting, and reporting any instances of modern slavery is the responsibility of everyone at Hives Lodges.
  3. We encourage employees to report any suspicions or breaches of this policy promptly using our confidential Whistleblowing hotline.
  4. Employees should feel confident in raising any concerns related to modern slavery within our operations or supply chains without fear of retaliation.
  5. All reported issues will be investigated thoroughly, and appropriate actions will be taken to address them.
  6. Investigation outcomes will be communicated to the relevant management staff, with regular updates provided to the Risk Committee to ensure ongoing policy effectiveness.
  7. We are committed to protecting individuals who raise genuine concerns from any negative consequences or retaliatory actions.

 

Breaches of this policy
  1. Breaches of this policy by employees will result in disciplinary action, which may include dismissal for serious offenses.
  2. Hives Lodges
    may sever ties with any third parties found in breach of this policy.
Policy Administration
  1. The management holds overall accountability for ensuring the policy meets our ethical and legal obligations.
  2. Day-to-day responsibility for implementing and monitoring this policy lies with the Compliance Manager, who will also handle any related inquiries.
  3. The policy will undergo an annual review to ensure it remains effective and up to date.
  4. We invite all employees to share suggestions on improving the policy with the Compliance Manager.
  5. Any deviations from the policy require written consent from the Risk Committee and approval from the Board for significant changes.