Modern Slavery Policy
Flow Associates
Reviewed February 2025
1. Overview and how we define Modern Slavery
1.1 Slavery, forcedlabour, servitude, and human trafficking are types of ‘Modern Slavery’ – criminal activity that deprives victims of their liberty and usually involves
financial and other exploitation.
1.2 We conduct our business fairly, ethically and with respect to
fundamental human rights. We are committed to the prevention of all forms of
Modern Slavery, both in our business and in our supply chains. We will not
tolerate it.
1.3 You must read and comply with this policy if you work for, or
on behalf of us in any capacity including as: an employee, director, officer,
worker, consultant, volunteer, supplier or service provider.
1.4 Failure to comply with this policy may result in disciplinary
action, including dismissal, or termination of the contract between you and us.
It could also involve other legal steps being taken against you.
1.5 Our Anti-Slavery Officer (‘ASO’) is [ALEX FLOWERS]. They are responsible for this policy.
1.6 If you are an employee, this policy does not form part of your
employment contract, and we may update it at any time.
1.7 Our ASO will update this policy and guidance annually and make it publically available on the Flow Associates website.
1.8 Flow Associates are a Limited Company in the UK conducting research, consultation and public engagement. Our three directors hold the ultimate control of the company and responsibility for upholding our policies and ensuring that all we work with are in alignment with them.
2. Preventing Modern Slavery in our business
2.1 We carry out appropriate checks on all employees and suppliers, so that we know who is working for us or on our behalf.
2.2 We give every employee a written employment contract, and he
or she is paid in accordance with the law. We comply with our legal obligations
to ensure the health and safety of all of our employees and workers, including
in relation to working hours, rest breaks and holidays.
2.3 All directors, managers, staff and associates are provided with training on this policy upon commencement of association. Our ASO is willing to provide further training or answer queries at any time.
3. If you are one of our Suppliers
3.1 If you supply us with goods or services, you must assess your business and supply chains and confirm to our ASO that you:
● Comply with your legal obligations, in relation to Modern Slavery; and
● Are committed to ensuring there is no Modern Slavery taking place in your business, or in any of your supply chains.
3.2 If you breach this policy, or are found to have Modern Slavery in your business, or knowingly in your supply chain, we may terminate our contract with you and pursue legal remedies against you.
4. If you are an Employee or a Worker providing services for us
4.1 You must immediately report any suspicions of Modern Slavery
in our business or supply chains to our ASO. Our ASO will investigate and
report to our Board of Directors within a reasonable time, on actions which may
require to be taken.
4.2 You will not suffer any detrimental treatment as a result of
reporting any genuine concerns, raised in good faith, under this policy. This
applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately tell our ASO.