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Anti-Slavery Policy

It is our approach to comply with all laws and regulations relevant to our business in all countries where we operate. Following the implementation of the Modern Slavery Act 2015, we are fully committed to maintaining and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.

Modern slavery is criminal activity and a violation of human rights. The deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain is unacceptable. For these reasons, slavery and human trafficking is a matter of zero tolerance for our practice.

All staff involved in the engagement of suppliers must communicate our zero tolerance approach to all prospective parties at the outset of our business relationship and monitor our approach as appropriate thereafter.

In addition our sub consultants/third party checklist will highlight this policy and our approach to all prospective or current subs consultants/ third parties engaged.  We may terminate our relationship with third parties engaged with us if they do not comply with this Policy.

This Policy applies to all members, employees, agents, consultants and those parties in our supply chain, wherever in the world they operate. Any reported breach of this Policy will be investigated and may lead to disciplinary action which subsequently could result in employee dismissal.

Responsibility for reporting incidents of slavery

 The detection and reporting of slavery is the responsibility of all of us. You should raise any concerns about any issue or suspicion of modern slavery in any part of our business or supply chain at the earliest possible stage. Suitable channels of communication by which you can report confidentially any suspicion of slavery are detailed in firm’s Whistleblowing Procedure, which can be found in our handbook.

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 our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

You must notify your Associate OR a Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.  

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our 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 your Associate or Director OR report it in accordance with our Whistleblowing Policy as soon as possible.  

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our 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 our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.  

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 your Associate immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.      

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. 

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. 

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Paul Crowe BA (Hons) DipArch RIBA MRIAI
For TODD Architects