Slavery And Human Trafficking Policy

CMD Ltd strictly prohibits the use of modern slavery and human trafficking within our operations and supply chain. We are and will continue to be committed to implementing systems and controls aimed at ensuring modern slavery does exist within or affect our operations or supply chain.

This policy applies to all persons working for CMD Ltd or on our behalf in any capacity, including employees at all levels, agency workers, agents, contractors and suppliers.

CMD Ltd strictly prohibits the use of modern slavery and human trafficking within our operations and supply chain. We are and will continue to be committed to implementing systems and controls aimed at ensuring modern slavery does exist within or affect our operations or supply chain. We expect that our suppliers will hold their own operation and suppliers to the same high standard.

Modern Slavery and Human Trafficking

Modern Slavery is a term used to encompass, slavery, servitude, forced, sweated and compulsory labour, bonded and child labour and human trafficking – where a person arranges or facilitates the travel of another person with a view to that person then being exploited into forced labour.

Commitments

We are a company that requires everyone working within CMD or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery within our organisation and supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our clients, stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We take a risk based approach to our processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct.
  • Consistent with our risk based approach we may require:
    • Suppliers and recruitment agencies and other third parties supplying services to CMD Ltd to confirm their compliance with this Code of Conduct
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to our Code of Conduct
  • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.