Modern Slavery Policy

We are committed to implementing and enforcing effective systems and controls which aim to ensure modern slavery is not taking place within Search Laboratory, or in our supply chains. This policy offers examples of what constitutes modern slavery and explains the responsibilities of Search Laboratory’s employees and related persons under this policy. It also sets out the procedure for raising concerns if you believe there has been a breach of this policy.


The Modern Slavery Policy applies to all Search Laboratory employees, but also anyone working on Search Laboratory’s behalf, including agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.


What is Modern Slavery and how can it happen?

Modern slavery 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. Modern slavery is a crime and a violation of fundamental human rights.


By way of example, a person coming from a situation of poverty and lack of opportunity might get an offer of an apparently good job in the UK. Often the victim has to take a loan from an agent to pay for the journey and recruitment fees. When the person arrives in Britain, the job and the conditions they were promised are completely different: their passport is taken away and they’re told they need to pay off the debt before they can leave. Violence or threats are common practice, both against the victim as well as their family back home.


Our contractors, suppliers and other business partners, are upheld to specific prohibitions against the use by them of forced, compulsory or trafficked labour; or anyone held in slavery or servitude. We expect our suppliers to hold their own suppliers to the same high standards.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within Search Laboratory’s supply chains constitutes any of the various forms of modern slavery, you should immediately raise your concerns with HR or a Director.


Examples include:

  • You notice one of Search Laboratory’s contractors looks fearful and anxious. They appear withdrawn and are avoiding eye contact, and do not appear to be in control of their own affairs (for example, they are not in control of their money, they are picked up and dropped off at work and are not allowed or able to speak alone or for themselves)
  • One of Search Laboratory’s suppliers mentions they have just visited their factory in China, where the conditions of the factory are dirty and cramped, and there are employees living and working in the same place.

Responsibility for this Policy

The board of Directors has overall responsibility for ensuring this policy complies with applicable legal and ethical obligations, and that all those under Search Laboratory’s control comply with it.


The Compliance Team 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.


Management at all levels is 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 in supply chains.


Communication and awareness of this Policy

Search Laboratory’s commitment to addressing the issue of modern slavery in its business and supply chains should be communicated to suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.


Raising a concern

The prevention, detection and reporting of modern slavery in any part of Search Laboratory’s business or supply chains is the responsibility of all those working for it or under its control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.


If you believe or suspect any modern slavery in any part of Search Laboratory or its suppliers’ businesses, or that any other breach of this policy has occurred or may occur, you must report it in accordance with the Whistleblowing Policy as soon as possible.


Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

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