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Modern Slavery and Human Trafficking Policy

Modern Slavery and Human Trafficking Policy

Policy Summary

This policy sets out our zero tolerance approach to modern slavery and human trafficking within our business and from within our supply chains.


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 to exploit them for personal and commercial gain.

Distinct is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. 

This statement is published in line with section 54(1) of the Modern Slavery Act 2015.


Our Commitment 


Our People

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.


Our Supply Chains

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour. The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers or goods and services to the organisation.

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains. Our supply chains are limited and we procure goods and services from a restricted range of UK and overseas suppliers. However, we are committed to procuring our suppliers ethically in line with our Environmental, Social and Governance commitments, as set out in our ESG policy.

We expect the same high standards from all our contractors, suppliers, and other business partners.


Embedding the principles of the Modern Slavery Act 2015

We will continue to embed the principles through:

  • providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
  • continuing to take action to embed a zero tolerance policy towards modern slavery
  • ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices


Monitoring and Enforcement

If any of our employees think they have come across an instance of modern slavery or if in fact you are a victim yourself, please follow the Whistle Blowing procedure and phone the Modern Slavery Helpline on 0800 0121 700 for information and guidance. 

The Board has overall responsibility for the effective operation of this policy.

Line managers have day-to-day responsibility for this policy and you should refer any questions about this policy to them in the first instance.


Review and maintenance

This statement will be reviewed, agreed and updated every year.




Equality, equity, diversity, and inclusion

Equality: the state of being equal, especially in status, rights, or opportunities.

Equity: refers to fairness and justice and recognising that we do not all start from the same place and must acknowledge and make adjustments to imbalances.

Diversity: the existence of variations of different characteristics in a group of people. These characteristics could be everything that makes us unique, such as our cognitive skills and personality traits, along with the things that shape our identity (e.g. race, age, gender, religion, sexual orientation, cultural background).

Inclusion: actively embracing people with diverse perspectives, backgrounds. and experiences.

Unlawful discrimination

When a person or group of people is treated less favourably than another person or group of people would be treated based on their protected characteristic.

Types of discrimination

  •   Direct discrimination – treating someone unfairly because of their protected characteristic.
  •   Indirect discrimination – A practice, policy or rule applied to everyone that may at first appear fair or neutral but puts people of a particular protected characteristic at a disadvantage.
  •   Discrimination by association – a person is treated unfavourably because of another person’s protected characteristic.
  •   Discrimination by perception – when someone is treated unfairly because others believe they have a protected characteristic.
  • Victimisation – a person is treated less favourably because they have or is expected to complain about discrimination.
  • Harassment – unwanted conduct that has the purpose or effect of violating a person’s dignity by creating an intimidating, hostile, degrading, humiliating or offensive environment.
  • Bullying – persistent, offensive, abusive, intimidating or insulting behaviour, abuse of power or unfair sanctions which make the recipient feel upset, threatened, humiliated or vulnerable, which undermines their self confidence, and which may cause them to suffer stress.

Each of the above, are grounds covered by current anti-discrimination legislation in the UK.


Equality Impact Assessment

An evidence-based approach designed to help ensure that policies, practices, events, and decision-making processes are fair and do not present barriers to participation or disadvantage any protected groups from participation.


Our people include employees (whether part time, full time, fixed term or permanent); casual workers, agency workers, contractors, delegates on secondment, volunteers, interns, apprentices, job applicants, third-party providers and partners.


A preconceived opinion that is not based on reason or actual experience.

Reasonable Adjustments

Under anti-discrimination legislation (Equality Act 2010) employers are required to make reasonable adjustments for disabled staff. This means making changes to a disabled person’s environment or the way their employment is structured to mitigate any disadvantages and allows them to work safely and productively. This may include, for example, removing physical barriers, providing extra support, and providing flexibility.