Modern Slavery Statement

Thomas Gray policies include our Modern Slavery and Human Trafficking Policy where we confirm our zero-tolerance approach which applies to all persons working for us or on our behalf in any capacity, including employees at all levels.

We also operate a Whistleblowing policy to support and encourage our staff to report any wrongdoing which extends to Human Right violations like Modern Slavery.

Thomas Gray consider that modern slavery encompasses:
Human Trafficking
Forced to work through physical or mental abuse
Dehumanised, treated as a commodity or bought and sold as ‘property’
Physically constrained or have restrictions placed on their freedom of movement.

Our Policy
We are committed to ensuring that we take all reasonable steps to ensure that there is no modern slavery or human trafficking within our business. Our Policies on Tackling Hidden Labour Exploitation and Ethical Trading reflect our commitment to acting with integrity and ensuring that our systems and controls are effective in identifying any potential risks in relation to modern slavery and human trafficking.

Due Diligence Process
As part of our own business we supply temporary personnel to several clients. In this respect we have established and audited procedures to ensure that those employees: –
• have a right to work in the UK. This involves asking the individual direct to view their passport. A delay in providing the passport might indicate a modern slavery issue;
• where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and
• where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.

In addition, our employees, through the Employee Code of Conduct, are made aware of Thomas Gray’s requirement for employees to support and uphold human rights principles and know that Thomas Gray will not tolerate, engage in or support the use of, forced labour.

Supply Chains
As a professional services firm, we engage in a small number of other firms associated with services delivered to our offices such as cleaning, marketing materials and technology.

Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.