WIL-LEC GRP LTD T/A WIL-LEC GROUP
MODERN SLAVERY & HUMAN TRAFFICKING POLICY
POLICY STATEMENT
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 in order to exploit them for personal or
commercial gain.
The Wil-Lec group (“Wil-Lec”) is committed to acting ethically and with integrity in all its business dealings and relationships. It has designed systems and controls aimed at assessing and reducing the risk of modern slavery taking place in its own business and in its supply chains.
Wil-Lec is also committed to ensuring there is transparency in its own business and in its
approach to tackling modern slavery throughout its supply chains, consistent with the disclosure
obligations under the Modern Slavery Act 2015 and our full modern slavery statement can be found
online at www.wil-lec.co.uk Wil-Lec expect the same high standards from all of its contractors,
suppliers and other business partners, and as part of its contracting processes, Wil-Lec includes
specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in
slavery or servitude, whether adults or children. Wil-Lec expects that its suppliers will hold their
own suppliers to the same high standards.
This policy applies to all persons working for Wil-Lec or on its behalf in any capacity, including
employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns,
agents, contractors, external consultants, third-party representatives and suppliers.
This policy does not form part of any employee's contract of employment and may be amended at
any time.
Responsibility for the Policy
The board of directors has overall responsibility for ensuring this policy complies with Wil-Lec’s
legal and ethical obligations, and that all those under Wil-Lec’s control comply with it.
The Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and overseeing the auditing of internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels across the Wil-Lec Group 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.
Wil-Lec August 2021
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 Wil-Lec head office legal department.
Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of the business or supply
chains is the responsibility of all those working for Wil-Lec or under Wil-Lec’s control. You are
required to avoid any activity that might lead to, or suggest, a breach of this policy.You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts
of the business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify
the Wil-Lec legal department or report it in accordance with the Wil-Lec’s Whistleblowing Policy,
as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, Wil-Lec will give support and guidance to its suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their
working conditions within any tier of the Wil-Lec supply chains constitutes any of the various
forms of modern slavery, raise it with the Wil-Lec legal department.
Wil-Lec aims 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. Wil-Lec is 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 its own business or in any of its 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 relevant HR Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally in accordance with the Wil-Lec Grievance Policy and Procedure, which can be obtained from the office or by contacting the HR Manager.
Communication and awareness of this Policy
Communication of this policy forms part of the induction process for all individuals who work for us,
and regular training will be provided as necessary.
Wil-Lec’s zero-tolerance approach to modern slavery must be communicated to all suppliers,
contractors and business partners at the outset of the business relationship with them and
reinforced as appropriate thereafter.
Wil-Lec August 2021
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal
for misconduct or gross misconduct.
Wil-Lec may terminate its relationship with other individuals and organisations working on its
behalf if they breach this policy.
Signed - ………… Date -24th March 2024
Steve Wilson – WIL-LEC GROUP - Managing Director