Anti-Slavery and Human Trafficking Policy

Operating as a logistics business in the UK, SKU Logistics maintains relationships with companies and key people throughout the supply chain and employs between 40-60 members of staff directly across two sites.

In line with the Modern Slavery Act 2015, SKU Logistics (‘We’, ‘Our’) has outlined its anti-slavery policy below. All entities that are currently in a business relationship, or are seeking to initiate a business relationship, should be aware of the following policy and adhere to it at all times.

1. Policy Statement

1.1  Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our organisation.

1.2  We are also committed to ensuring there is transparency in our business throughout our approach to tackling modern slavery. This is consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, We include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and We expect that our suppliers will hold their own suppliers to the same high standards.

1.3  This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, contractors, external consultants and third-party representatives and business partners.

1.4  This policy does not form part of any employee’s contract of employment and SKU Logistics may amend it at any time.]

1.5 Our anti-slavery policy prohibits any employee, or agency worker working on Our behalf, from:

a.  working in unsafe or hazardous conditions without the required training and protective equipment,

b.  working more than 48 hours per week or 60 with overtime,

c.  working whilst under the minimum age,

d.  working without being duly inducted and trained.

2. Responsibility for the Policy

2.1  The board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2  The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3  The anti-slavery due diligence process will be conducted regularly by the compliance manager; the process is to include:

a.  Regular updates to SKU Logistics’ Modern Slavery Policy to ensure compliance with the latest government guidance and legislation,

b.  Identification of modern slavery risks throughout the structure of the organisation,

c.  Assessing supplier, third party organisations and contractor’s modern slavery policies, and identifying high risk organisations,

d.  Engaging with organisations SKU Logistics has a relationship with throughout the supply chain, whilst We recognise We cannot control the policies of other organisations We can perform risk assessments and share our policies.

2.4  Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

2.5  You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.

3. Compliance with the policy

3.1  All employees, contractors, agency staff, suppliers and business partners must ensure that they read, understand and comply with this policy.

3.2  The prevention, detection and reporting of modern slavery in any part of our business is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3  You must notify your manager or the compliance officer as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

3.4  You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest possible stage.

3.5  If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it to the compliance officer at the earliest possible opportunity.

3.6  If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our suppliers constitutes any of the various forms of modern slavery, raise it with your manager or the compliance officer.

3.7  We aim to encourage openness and our whistleblowing process will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our group. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the business Grievance Procedure.

3.8  Please visit the SKU Logistics website for contact details if you wish to raise a concern regarding this policy:

3.9 At the point of last review (August 2022) there have been no issues, concerns or queries brought to the attention of the management team or the compliance officer.

4. Communication and Awareness of this Policy

4.1  Training on this policy, and on the risk our business faces from modern slavery, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

4.2  Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this Policy

5.1  Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2  We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

5.3  Any concerns or issues raised by an employee regarding this policy or anti-slavery that are found to be malicious or made with ill intent will result in appropriate disciplinary action being taken.

6. Review of the Policy

6.1  This policy will be reviewed by SKU Logistics’ board of directors on a regular basis (at least annually) and will be kept up to date by the compliance officer.

6.2 Next review: August 2023.


Rick Jones, MD.