Angus & Carr Modern Slavery Policy

1. Purpose

Angus & Carr is committed to conducting business lawfully, ethically and with integrity. We do not tolerate modern slavery, forced labour, child labour, human trafficking, debt bondage, servitude, slavery-like practices or any other exploitation of workers in our operations or supply chains.

This Policy sets minimum standards for Angus & Carr and our partners, employees, contractors, consultants, agents, recruiters, suppliers, subcontractors and other business partners. It supports Angus & Carr’s commitment to identify, assess and address modern slavery risks in its direct operations and supply chains.

2. Scope

This Policy applies to:

  • all partners, employees and contractors of Angus & Carr

  • all consultants, agents and intermediaries acting for or on behalf of Angus & Carr

  • all suppliers, service providers, recruiters, labour hire providers and subcontractors engaged by Angus & Carr

  • all workers engaged in connection with Angus & Carr’s operations or supply chains

3. Policy Statement

Angus & Carr prohibits all forms of modern slavery and labour exploitation. No person covered by this Policy may engage in, facilitate, support, benefit from or ignore conduct prohibited by this Policy.

Compliance with this Policy is a condition of employment, engagement and ongoing business relationship with Angus & Carr.

4. Definitions

Modern slavery includes trafficking in persons, slavery, servitude, forced labour, debt bondage, deceptive recruiting, the worst forms of child labour and other slavery-like exploitation.

Child labour means work performed by a person below the minimum age for completing compulsory schooling and, in general, below 15 years of age, except where a lawful and appropriately safeguarded exception applies.

Worst forms of child labour includes slavery or practices similar to slavery involving children, including sale and trafficking, debt bondage, forced labour, use of a child for prostitution or pornography, and hazardous work or work under particularly difficult conditions that may harm a person under 18 years of age.

Recruitment fees means any fees or costs charged to a worker or potential worker for recruitment or access to work, whether directly or indirectly.

5. Prohibited Conduct

5.1 Forced labour and trafficking

No person covered by this Policy may engage in, support or benefit from:

  • forced or compulsory labour

  • slavery, servitude or debt bondage

  • human trafficking

  • deceptive recruitment

  • coercion, threats or abuse to compel work

  • exploitation of a person’s visa or migration status

5.2 Worst forms of child labour

No person covered by this Policy may engage in or tolerate:

  • hazardous work by persons under 18

  • work under particularly difficult conditions such as excessive hours or night work

  • use of a child for prostitution or pornography

  • trafficking or forced labour involving children

5.3 Child labour

No person covered by this Policy may engage in or facilitate child labour below the minimum legal working age or below the age for completing compulsory schooling, and generally not less than 15 years.

5.4 Withholding documents

No person may confiscate or restrict access to a worker’s passport, identity documents or immigration documents. Where documents are stored, access must remain free and immediate.

5.5 Recruitment fees

No recruitment fees or related costs may be charged to workers. All such costs must be borne by the employer or engaging entity.

5.6 Commercial sex acts

No person may procure or facilitate commercial sex acts in connection with work, business travel, supplier engagement or any contractual relationship with Angus & Carr.

5.7 Discrimination and retaliation

No person may discriminate in recruitment, employment or termination on the basis of:

  • race or colour

  • sex

  • religion

  • political opinion

  • national extraction or nationality

  • age

  • HIV/AIDS or medical status

  • disability

  • sexual orientation

  • family responsibilities

  • trade union membership or activities

Retaliation against any person raising concerns or exercising workplace rights is prohibited.

6. Worker Rights and Minimum Standards

6.1 Freedom to leave employment

Workers may terminate employment at any time without financial penalty, subject only to lawful notice requirements.

6.2 Wages

Workers must be paid at least the applicable legal minimum wage or prevailing sector wage where no legal minimum applies. Unlawful deductions or withholding of wages are prohibited.

6.3 Freedom of association

Workers have the right to:

  • form and join trade unions

  • bargain collectively

  • engage in lawful industrial activity

6.4 Work agreements

Workers must receive clear written agreements before work begins, in a language they understand, covering key employment terms.

6.5 Housing

Any housing provided or arranged must meet applicable legal, health and safety standards and be safe and suitable.

7. Recruitment and Right to Work

7.1 Worker verification

Angus & Carr will verify identity, age and legal right to work before engagement.

7.2 Right to work

Workers must have valid legal authority to work for the duration of their engagement.

7.3 Young workers

Additional safeguards apply where workers are under 18 to ensure lawful and safe work.

8. Supplier and Recruiter Due Diligence

8.1 Risk assessment

Suppliers must complete a modern slavery risk assessment prior to onboarding and at least annually thereafter.

8.2 Contractual requirements

Suppliers may be required to:

  • comply with this Policy

  • notify Angus & Carr of breaches

  • cooperate with audits and investigations

8.3 Mandatory supplier policies

Suppliers must maintain written policies addressing:

  • modern slavery and forced labour

  • child labour and worst forms of child labour

  • recruitment practices and prohibition on fees

  • withholding of documents

  • discrimination

  • wages and working conditions

  • freedom of association

  • worker contracts and documentation

  • housing standards

  • prevention of coercion and exploitation

8.4 Evidence and verification

Suppliers must provide evidence of compliance and may be subject to audit or review.

8.5 Flow-down obligations

Suppliers must ensure that equivalent obligations are contractually imposed on subcontractors and that those subcontractors comply in practice.

Suppliers must monitor compliance and address non-compliance. Failure may result in termination of the engagement.

9. Continuous Improvement – Direct Operations

Angus & Carr will continuously identify and address modern slavery risks in its operations through risk assessments, monitoring, training and policy updates.

10. Continuous Improvement – Supplier Engagement

Angus & Carr will continuously improve its supplier due diligence processes through ongoing assessment, monitoring, engagement and review of supply chain risks.

11. Training and Awareness

Angus & Carr will provide mandatory annual modern slavery training to relevant personnel.

Training will cover:

  • modern slavery risks and indicators

  • obligations under this Policy

  • reporting processes

Training will be tailored to role and risk exposure, and regularly updated.

12. Reporting and Grievance Mechanism

12.1 Reporting channels

Workers and agents may report concerns through designated contacts, email or anonymous channels where available.

12.2 Non-retaliation

No person will be subject to retaliation for raising concerns or participating in investigations.

12.3 Confidentiality

Reports will be handled confidentially where reasonably practicable.

12.4 Investigation

All reports will be assessed and investigated appropriately, with priority given to worker safety.

12.5 Supply chain access

Suppliers must provide equivalent reporting mechanisms and ensure workers can raise concerns without penalty.

13. Accountability and Enforcement

13.1 Compliance obligation

Compliance with this Policy is mandatory.

13.2 Investigation

Suspected breaches will be assessed and investigated proportionately.

13.3 Disciplinary action

Breaches may result in:

  • warnings or training

  • suspension

  • termination of employment or engagement

  • referral to authorities

Serious breaches will be treated as gross misconduct.

13.4 Supplier action

Non-compliant suppliers may be subject to:

  • corrective action plans

  • increased monitoring

  • suspension or termination

13.5 Remediation

Where harm occurs, Angus & Carr will take steps to:

  • support affected workers

  • correct the issue

  • prevent recurrence

13.6 Continuous improvement

Findings from incidents and investigations will be used to strengthen systems and controls.

13.7 Record-keeping

Records of reports, investigations and outcomes will be maintained and reviewed.

14. Governance and Review

Angus & Carr will:

  • communicate this Policy

  • support implementation through procedures and templates

  • review this Policy annually or as required

15. Contact

Questions or concerns regarding this Policy may be directed to clientcare@angusandcarr.com.