Modern Day Slavery Policy

The scope of the policy applies to CMG, its subsidiaries, employees, franchise & manufacturing partners, suppliers of goods and services engaged in business with Cowan Recovery Limited t/a CMG.

The policy covers Modern Day Slavery and Human Trafficking in accordance with the Modern Day Slavery Act 2015 and sets out the steps the company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Modern Day Slavery and Human Trafficking can take on many forms such as Slavery, servitude, forced labour, compulsory labour and human trafficking. This may manifest itself practically in instances of restricted freedom of movement or decision making by individuals, the provision of shared accommodations and central payment for services to a single person (for paying individuals later).

Such activities are an affront to human dignity, an offence in UK Law and completely contrary to the values of CMG.

CMG is committed to complying with its obligation under the Modern Day Slavery Act and other relevant legislation relating to the detection and prevention of modern slavery. In particular CMG is committed to implementing and enforcing effective systems and controls that seek to ensure that modern slavery is not taking place anywhere in its business or in its supply chains.

Policy

The company has zero tolerance to breaches in the Modern Day Slavery Act and has in place polices, processes, whistleblowing and auditing procedures to ensure that any organisation within the scope of our policy who transact business with CMG complies with it.

The company expects that any organisation within the scope of the legislation will also apply the same high standards.

Compliance

The company will maintain its compliance with the policy as follows:

1. Maintaining and updating HR polices in line with legislation and best practice

2. Following our CMG recruitment polices

3. Recruiting as a minimum to the National Minimum Wage level and achieving the National Living wage within 12 months of joining the company

4. Tracking, monitoring and preventing the risk of occurrence through diligent management.

5. Audit where applicable.

6. Investigating thoroughly any issues/concerns detected.

7. Apply sanctions against these supplier organisations who do not conform to legal requirements.

8. Communicating with employee

9. Provide appropriate / relevant training and guidance to employers

10. Provision of a confidential whistleblowing service

Procedure

Our recruitment process is transparent with appointments to the business approved by Directors. There are robust procedures in place for the vetting of new employees that enable us to confirm their identities and ensure they are both paid directly and correctly.

All departments entering into business relationships with suppliers, contractors and business partners are to at the outset of our business relationship with them provide them with a copy of this policy. Also, a completed Supplier Conformation Statement. (see attached pro forma) is to be completed. CMG Business Development will manage the relationships to retain evidence that this conformation has been obtained from the supplier, contractor or business partner with whom we receive supply or service from them.

Implementation

CMG will be responsible for implementing this policy, ensuring that all colleagues are aware of he policy by making it available on the company systems.

CMG will ‘train out’ this policy during employee induction training.

Managers and their teams will be responsible for ensuring that CMG has a record for suppliers within the scope of this policy assigned CMG declaration

of compliance.

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. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issues of modern slavery in supply chains.

The prevention, detection and reporting on modern slavery in any part of the companies business is the responsibility of all those working for the company or under the companies control. You are required to avoid any activity that may lead to a breach of this policy.

The company will introduce appropriate arrangements to monitor the application of and use of this policy, dealing with any queries about this policy, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Communication and Awareness of this Policy

The Board of Directors will communicate the policy in accordance with statutory legislation.

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 regular training will be provided as necessary.

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

Reporting of Breaches

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or director. These breaches (suspected or actual) are to be passed to Business Development/Support Services departments so that they can be reported to the national authorities (as required by the National Referral Mechanism (NRM)).

You are encouraged to raise concerns about any issue or suspicion of modern day slavery in any part of the companies business as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the companies supply chains constitutes any of the various forms of modern day slavery, please raise it with your line manager or alternatively by use of the whistle blowing process.

CMG will support anyone who raises a genuine concern in good faith under this policy. The company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern day slavery is, or may be taking place in any part of our business or supply chain.

Breaches of the Policy

Any breach of our modern day slavery policy by any employee will result in use of the conduct code and could result in dismissal for gross misconduct.

The company will terminate any commercial relationships with suppliers if they are in breach of our policy and/or found to have been involved in modern slavery.