Anti-Slavery and Human Trafficking Policy


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.

Nuvias UC has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is
not taking place anywhere in our own business or in any of our supply chains. Nuvias UC is also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. Nuvias UC expects the same high standards from all our customers, vendors and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. This policy applies to all persons working for Nuvias UC or on behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, apprentices, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form any employee’s contract of employment and Nuvias UC may amend it at any time.

Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The CEO has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 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. All Nuvias UC employees 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 CEO.

Compliance with this Policy

All Nuvias UC employees must ensure that they 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.

All Nuvias UC employees must notify their manager or the CEO as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. All Nuvias UC employees 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 any Nuvias UC employee believes or suspects a breach of this policy has occurred or that it may occur, they must notify their manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If any Nuvias UC employee is 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 their manager or the
CEO. Nuvias UC 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. Nuvias UC 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 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 they believe that they have suffered any such treatment, they should inform the People & Development Manager immediately. If the matter is not remedied, and they are an employee, they should raise it formally using Nuvias UC Grievance Policy

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 Nuvias UC, and regular training will be provided as necessary. Nuvias UC’s 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 Nuvias UC employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Nuvias UC may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. This policy statement will be subject to regular review and amendment as often as may be appropriate. A copy will be issued to all employees and displayed around the sites and site offices.