Modern Slavery Statement
GAIN is committed to upholding the highest standards of human rights and ensuring that all individuals are treated with dignity, fairness, and respect. The company recognises the significant global issue of modern slavery and human trafficking and is dedicated to preventing these practices within our operations and supply chains.
Modern slavery is a crime and a violation of fundamental human rights, encompassing practices such as forced labor, human trafficking, and other forms of exploitation. This policy sets out GAIN’s commitment to combat modern slavery and the steps we are taking to ensure that slavery and human trafficking are not present within our business operations.
Purpose
The purpose of this policy is to:
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Ensure that GAIN adheres to legal and ethical standards with respect to modern slavery and human trafficking.
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Promote a clear understanding of the company’s commitment to eliminating modern slavery from all aspects of its operations.
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Provide guidance on how to identify and address risks of modern slavery within our business and supply chains.
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Foster transparency and accountability across the organisation, ensuring continuous improvement and adherence to anti-slavery principles.
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Contribute to the fight against modern slavery by supporting efforts to raise awareness, educate stakeholders, and advocate for change.
Objectives
The key objectives of this policy are to ensure:
Compliance with Legal Requirements: Ensure that GAIN complies with relevant anti-slavery and human trafficking laws, including the Modern Slavery Act 2015 (UK), the California Transparency in Supply Chains Act (USA), and other applicable local, national, and international laws.
Prevention of Modern Slavery:
Establish and enforce robust mechanisms to prevent modern slavery in our
operations and supply chains, including regular risk assessments and due diligence processes.
Awareness and Training:
Raise awareness among employees, suppliers, and stakeholders regarding the risks and
signs of modern slavery and provide relevant training to identify and address such risks.
Supply Chain Accountability:
Ensure that our suppliers and partners uphold the same high standards of ethical
conduct and comply with anti-slavery practices. We will encourage our suppliers to implement their own anti-slavery policies and practices.
Reporting Mechanisms:
Provide clear, accessible, and confidential channels for reporting concerns about
modern slavery and human trafficking and ensure that any reports are investigated thoroughly and handled with appropriate action.
Scope
This policy applies to all employees, contractors, suppliers, and business partners of GAIN worldwide. It includes all aspects of our operations, including:
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Business Operations: All activities related to the production, delivery, and management of services within GAIN.
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Supply Chain: All third-party suppliers, vendors, service providers, and partners that are part of theproduction or delivery of services to GAIN.
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Partners and Affiliates: All joint ventures, subsidiaries, and any other business entities affiliated with GAIN where modern slavery risks may be present.
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Legal Requirements: Ensuring compliance with relevant anti-slavery and human trafficking laws in all territories where the company operates, including the Modern Slavery Act 2015 (UK), the California Transparency in Supply Chains Act (USA), and any other applicable local or international laws related to forced labour and human trafficking.
Responsibilities
Executive Committee (ExCo):
• Overall responsibility for ensuring that GAIN is compliant with all anti-slavery and human trafficking laws.
• Approving and supporting this policy and its implementation across the organisation.
• Reviewing annual statements to ensure transparency in our efforts to prevent modern slavery.
Senior Leadership Teams (OpCo and MCo):
• Implementing and overseeing the execution of the anti-slavery policy within their respective departments and ensuring that adequate resources are allocated for its enforcement.
• Ensuring that modern slavery is included as part of regular risk assessments and business operations reviews.
• Ensuring compliance with legal obligations and keeping up to date with relevant legislative changes.
Human Resources (HR) Department:
• Ensuring recruitment and labour practices comply with ethical standards and legal requirements.
• Providing training to employees on identifying and responding to modern slavery and human trafficking.
• Coordinating the investigation of any concerns or reports related to modern slavery within the workforce.
Procurement and Supply Chain Teams:
• Conducting thorough due diligence when selecting suppliers and partners to ensure that they comply with anti-slavery policies and laws.
• Monitoring supplier activities for signs of modern slavery and ensuring that contracts contain provisions that require suppliers to comply with relevant labour laws.
• Taking appropriate actions, including contract termination, in the event of non-compliance or discovery of modern slavery within the supply chain.
Employees and Contractors:
• Complying with the anti-slavery policy, reporting any suspected modern slavery practices, and engaging in training and awareness programs.
• Cooperating with investigations and taking personal responsibility for ensuring their own actions do not contribute to modern slavery.
Suppliers and Third-Party Partners:
• Adhering to GAIN’s commitment to combat modern slavery and ensuring that their own business operations comply with relevant labour and human rights standards.
• Cooperating with GAIN to provide information and evidence that verifies their adherence to anti-slavery practices.
Legal Requirements
This policy is designed to ensure compliance with the following legal obligations:
Modern Slavery Act 2015 (UK): As a UK-based company or entity operating in the UK, Gain will publish an annual slavery and human trafficking statement that outlines the steps we have taken to address modern slavery risks within our operations and supply chains.
California Transparency in Supply Chains Act: For companies with operations in California, Gain will disclose efforts to eradicate slavery and human trafficking from our supply chain, in accordance with the legal requirements of this Act.
International Labour Standards:
Compliance with international labour standards, including the International Labour Organization (ILO) conventions, which prohibit forced and child labour and guarantee freedom of association and collective bargaining rights.
Other Applicable Local, National, and International Laws: Gain will adhere to any additional legal requirements in other jurisdictions where we operate, including anti-slavery and human trafficking laws in countries like Australia, Canada, and the European Union.
Compliance and Audit
The Modern Slavery policy will be audited regularly to ensure compliance with internal standards, and other relevant regulations. Any discrepancies found during audits must be addressed immediately.