Anti-Slavery and Human Trafficking Policy

Cyber Universe Europe Ltd. upholds the highest ethical standards and maintains a zero-tolerance approach to modern slavery in all its forms. 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.

1) Definition of Modern Slavery

Modern slavery involves depriving an individual of their liberty for another's personal or commercial gain and constitutes a serious breach of human rights.

Under the UK Modern Slavery Act 2015, the following criminal activities are defined:

Slavery: Exercising powers of ownership over an individual.
Servitude: Coercing an individual to provide services under obligation.
Forced or Compulsory Labour: Work performed involuntarily under threat or penalty.
Human Trafficking: Arranging or facilitating travel with the intention of exploiting the individual.
Child Labour: Engaging children in exploitative, harmful, or hazardous activities that interfere with their education, development, health, or overall well-being.

2) Embedding This Policy in Practice

Tackling modern slavery requires constant vigilance across all areas of our business and supply chain. To support the commitments set out in this policy, we will implement the following measures:

Regular Risk Assessments: To systematically identify and address areas of our business and supply chain at the highest risk.
Direct Engagement: Where necessary, we will engage with suppliers to understand their processes and controls relating to modern slavery.
Due Diligence: We will maintain robust procedures to assess supplier and contractor compliance with ethical labour standards.
Clear Communication: Suppliers will be informed that modern slavery in any form will not be tolerated, and non-compliance will lead to contract termination.

3) Organisational Roles and Commitments

Management at all levels is responsible for ensuring that employees and others working on our behalf understand and comply with this Policy. Specific day-to-day operational oversight may be assigned to the required roles.

4) Management Commitments

Our management is committed to fostering an environment built on trust and safety , ensuring staff feel supported and encouraged to report concerns. This includes:

Approachability: Listening and being approachable to colleagues.
Response: Responding appropriately to any information indicating an exploitative situation.
Vigilance: Remaining alert to indicators of modern slavery.
Awareness: Raising awareness through discussion and training so all staff can recognise signs of trafficking or exploitation.
Professional Judgment: Using professional judgment and experience to assess situations and act decisively.

5) Communication and Employee Awareness Training

Senior Managers shall ensure effective communication of this policy and supporting processes across the organisation:

Induction Training: All relevant staff receive appropriate training during their induction period.
Refresher Training: Regular refresher training is provided to raise awareness of the broader issues of modern slavery.
Risk Recognition: Employees are equipped to recognise potential risks and indicators of exploitation within the business or supply chain.

6) Breaches of This Policy

Breaches of this policy are taken extremely seriously and will result in immediate action:

Employee/Director Breach: Any breach may result in disciplinary action under our Disciplinary Procedure.
Serious Breaches: May constitute gross misconduct, leading to immediate dismissal.
Co-operation: All individuals covered by this policy must cooperate fully with any internal or external investigation relating to suspected breaches.

7) Policy Review and Clarification

Review: This policy shall be reviewed annually and updated as necessary to ensure ongoing compliance with UK legislation and best practice.
Clarification: If any part of this policy is unclear, clarification should be sought from info@cyberuniverse.uk