Anti slavery and human trafficking policy
Who this policy applies to
This policy applies to anyone working for BMJ Group, or on behalf of BMJ Group, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. It sets out what everyone must do to prevent and address slavery and human trafficking. It also provides information and guidance about how to recognise and report any concerns or suspicions you may have if you believe or suspect that slavery or human trafficking is taking place in any part of our business or supply chain.
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of slavery and human trafficking is the responsibility of all those working for us or under our control.
BMJ Group’s position
Slavery is a crime and a violation of fundamental human rights. It can take various forms including slavery, servitude, forced or compulsory labour, and human trafficking. All of these have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Zero tolerance
We have a zero-tolerance approach to slavery and human trafficking. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We will continue to ensure that we apply the highest standards of ethical conduct and integrity in all our business activities in the UK and overseas.
Transparency
We are committed to ensuring there is transparency in our business and in our approach to tackling slavery and human trafficking throughout our supply chains.
Working with us
We expect the same high standards from all of our colleagues, suppliers and other business partners. 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. We expect those we work with to hold their own suppliers to the same high standards.
What you must do
The prevention, detection and reporting of slavery and human trafficking is the responsibility of all those working with us or under our control.
Prevention
You must not engage in any activity that might lead to, or suggest, a breach of this policy. If you think there might be a problem with this policy, or if you have any questions or concerns about it, you should speak to your line manager and/or our Director of Finance as soon as possible.
Detection
If you have a concern or suspicion that slavery or human trafficking might be taking place in any part of our business or supply chain, you must report it to your line manager and our Director of Finance at the earliest possible stage.
If you are unsure about whether or not a particular act, the treatment of workers more generally, or their working conditions constitutes slavery or human trafficking, we encourage you to still raise it with your line manager and our Director of Finance.
Reporting
If you believe or suspect that slavery or human trafficking might be taking place in any part of our business or supply chain, or that it may occur, you must report it to your line manager and our Director of Finance as soon as possible. If for any reason you feel unable to speak to your line manager or the Director of Finance about your concerns then we would encourage you to still report the matter in accordance with our Whistleblowing policy.
BMJ Group’s commitment to you
We aim to encourage openness and 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 slavery or human trafficking is (or may be) taking place. 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 our Director of People and Transformation immediately.
Our legal obligations
Under UK law, slavery, forced or compulsory labour and human trafficking are criminal offences. Large companies like BMJ Group with a global turnover above £36 million are legally required to publish a slavery and human trafficking statement on their website each financial year.
For more information about the steps we have taken to ensure there is no slavery or human trafficking in our business or supply chains you can view our most recent Anti Slavery & Anti Human Trafficking Statement here. This Statement has been approved by our Board of Directors. For further information please contact our Director of Finance.
Communication of this policy and our requirements
Training on this policy, and on the risk our business faces from slavery and human trafficking in our supply chains, is made available to employees who work for us. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.
Consequences of breaching this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other colleagues and organisations working on our behalf if they breach this policy.
Responsibility for this policy
Each person working for us or on our behalf (in any capacity) is responsible for ensuring that they comply with their obligations in this policy. However, the following are responsible for overseeing compliance with this policy generally and on a day-to-day basis:
Our Group Leadership Team
- Has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it
Our Director of Finance
- Has primary and day-to-day responsibility for managing BMJ Group’s reporting requirements in a timely fashion and 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 slavery and human trafficking.
Our 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 slavery and human trafficking in supply chains.
Contact us
If you have questions, comments or suggestions about this policy, please contact the Director of Finance.
