Simon newton london

Modern Slavery 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. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed 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.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our terms and conditions of business, we require compliance with this policy and the Modern Slavery Act 2015 which contains 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.

1.3 This policy does not form part of any employee's contract of employment and we may amend it at any time.


2.1 This policy applies to all persons working for us or on our behalf in any capacity, including (but not exclusively): employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners, wherever they may be located.


3.1 SNL (Simon Newton London) Ltd has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

3.2 SNL Ltd have 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.

3.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are provided with adequate and regular communications on it and the issue of modern slavery in supply chains.

3.4 This policy will be subject to annual reviews by SNL Ltd


4.1 All employees, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, must ensure that you read, understand and comply with this policy.

4.2 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 a breach of this policy.

4.3 You must notify SNL Ltd as soon as possible if you believe or suspect that a conflict with this policy is occurring, has occurred, or may occur in the future.

5.1 Raising staff awareness of the problem of modern slavery and human trafficking is a priority for SNL Ltd. SNL Ltd will ensure that a staff training plan is in place that covers all staff and targets training appropriately. In addition, communications on modern slavery will be provided as necessary to all employees.

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


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

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