Policy Reference: POL-AS
Revision: MTS-HB-AS-1.3
Revision Date: 25.10.2021
Company: Morpheus Talent Solutions Ltd

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms including slavery, servitude, forced or compulsory labour and human trafficking. All forms involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

Morpheus Talent Solutions Ltd operates a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.

We are committed to transparency in our business operations and to tackling modern slavery throughout our supply chains in line with the requirements of the Modern Slavery Act 2015.

We expect the same high standards from all contractors, suppliers and business partners. As part of our contracting processes, we include prohibitions against forced, compulsory or trafficked labour and expect our suppliers to hold their own supply chains to the same standards.

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

This policy does not form part of any employee’s contract of employment and may be amended at any time.

Responsibility for the Policy

Morpheus Talent Solutions Ltd has overall responsibility for ensuring this policy complies with legal and ethical obligations and that all individuals under our control comply with it.

The Company has day-to-day responsibility for implementing the policy, monitoring its effectiveness, addressing queries and auditing internal systems and procedures to ensure they effectively counter modern slavery risks.

Management at all levels are responsible for ensuring employees understand and comply with this policy and receive adequate and regular training on modern slavery risks within supply chains.

Employees are encouraged to provide feedback and suggestions on how the policy can be improved. Comments should be directed to the Company Directors.

Compliance with the Policy

All individuals must read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for or on behalf of Morpheus Talent Solutions Ltd.

You must avoid any activity that might lead to or suggest a breach of this policy.

You must notify your line manager or a Company Director as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.

Concerns about modern slavery practices in any part of the business or supply chains should be raised at the earliest possible stage.

If you believe a breach has occurred, you must report it immediately to your line manager, Company Director or through the Company’s Whistleblowing Policy.

Where appropriate, and with the welfare and safety of workers as a priority, the Company will provide support and guidance to suppliers to help them address exploitative or coercive labour practices.

If you are unsure whether working conditions or treatment of workers may constitute modern slavery, you should raise the matter with management.

The Company promotes openness and will support anyone who raises genuine concerns in good faith, even if those concerns later prove to be mistaken.

No individual will suffer detrimental treatment as a result of reporting concerns in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or unfavourable treatment connected with raising a concern.

If you believe you have suffered such treatment, you should inform your line manager immediately. If the matter is not resolved, employees should follow the Company’s formal Grievance Procedure.

This policy is intended for application in all countries in which Morpheus Talent Solutions Ltd operates, with particular relevance to the United Kingdom.

Communication and Awareness

Training on this policy and the risks of modern slavery in supply chains forms part of the induction process for all individuals working for the Company.

Updates and ongoing awareness will be communicated using established internal communication channels.

Our zero-tolerance approach must also be communicated to suppliers, contractors and business partners at the start of business relationships and reinforced where appropriate.

Breaches of this Policy

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

The Company may also terminate relationships with individuals or organisations working on its behalf if they breach this policy.

Policy Review

Morpheus Talent Solutions Ltd will review this Anti-Slavery Policy periodically to ensure it remains effective and up to date.