Introduction
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.
Customerwise 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.
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.
This policy applies to all persons working for Customerwise or on our 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 business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at
any time.
Responsibility for the Policy
The Company 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 Company 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.
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 Managing
Director.
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 line manager
or a company 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 line manager
or company 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 a 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 line manager
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.
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.
Last reviewed: 05/05/2026
Due to review: 05/05/2027