Anti-Slavery & Human Trafficking Policy Future Metals

Anti-Slavery Policy [UK] updated 05/15/2021

Anti-Slavery & Human Trafficking Policy Future Metals

1. Introduction
   1. Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights
   2. Forms of Modern slavery may include, but are not limited to, withholding of passports, being forced to work against a person’s will, depending on the employer for housing, food, and other necessities, being recruited through some form of debt arrangement, such as an advance or loan, and limitations on movement of workers.
   3. Future Metals UK strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold themselves and their own suppliers to the same high standards.
2. Policy Statement
   1. We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
      • We have a zero-tolerance approach to modern slavery in our organisation or our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
      • We are committed to engaging with our stakeholders and direct suppliers to address the risk of modern slavery in our operations and supply chain.
      • As part of our contracting processes, we include a specific prohibition against the use of modern slavery and trafficked labour and a requirement to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
      • Our recruitment procedures require employment and recruitment agencies and other third parties supplying workers to our organisation to comply with our Code of Conduct. Suppliers engaging workers through a third party are also required to obtain third parties’ agreement to adhere to the Code of Conduct.
3. Policy Application
   1. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, suppliers, external consultants, third-party representatives and business partners.
   2. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
   3. Workers must ensure that they read, understand and comply with this policy.
4. Responsibility for the policy
   1. The board of directors has approved this policy, is committed to making available sufficient resources for its implementation and has overall responsibility for ensuring compliance.
   2. The Corporate Secretary has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about this policy, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
   3. Management at all levels are 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.
   4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Corporate Secretary or your local HR representative.
5. Reporting Modern Slavery
   1. Employees must notify their manager or the Corporate Secretary or local HR representative as soon as possible if they have any reason to believe that modern slavery of any form may exist within our organisation or our supply chain, or may occur in the future or have any concerns or suspicions relating to compliance with this policy. Alternatively employees may raise concerns confidentially with the:Corporate Compliance Hotline
      + 1 704 752 9679
   2. If a person, other than an employee, has any reason to believe that modern slavery of any form may exist within our organisation or our supply chain, or may occur in the future or have any concerns or suspicions relating to compliance with this policy, they must notify as soon as possible the Corporate Secretary or the :Corporate Compliance Hotline
      + 1 704 752 9679
   3. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Corporate Secretary or local HR representative immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
6. Breaches of this policy
   1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
   2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.