MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Introduction

Modern Slavery and Human Trafficking remains a hidden blight on our global society.  We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.

Statement of Intent

Bugler Group is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We are also committed to acting ethically and with integrity, in all our business relationships and taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any sort of business relationship with our Company.  We expect our supply chain and contractors to comply with our values and to have appropriate policies and processes that address slavery and human trafficking.

As part of our initiative to identify and mitigate risk, the company has in place systems to encourage the reporting of concerns and the protection of whistleblowers.

This statement is made in accordance with Section 54 (1) of the Modern Slavery Act 2015 and constitutes the company’s Modern Slavery and Human Trafficking statement.

Policy Aims

Senior management will ensure that Bugler Developments:

• Monitor right to work documentation;
• Conduct payroll audits;
• Maintain a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations;
• Regularly review supply chain policies, codes of conduct and our working practices to demonstrate commitment.

This policy will be communicated to all employees and organisations working on our behalf and displayed at our offices and on our intranet.  This policy is available to defined interested parties.

This policy will be reviewed annually or sooner by senior management to ensure its suitability.  Where necessary it will be amended, reissued and communicated to all employees and people working on its behalf.