1. Overview
Optima Partners Limited (‘Optima’) is committed to ensuring that high legal, ethical, and moral standards are in place across the organisation.
We are proud of the conditions of employment for all our employees throughout the Company. Given the nature of our business, our board and management teams each consider that there is minimal risk approximating to no risk that, either within the Company or the very limited supply chains which support our business activities, that are in any way involved in or even tangentially supportive of, or complicit in slavery and human trafficking. The employment and procurement practices operated by the businesses within the Company ensure that the Company is rightly viewed as an excellent and supportive employer. And to the extent that the Company operates as a purchaser of goods or services we expect a high level of ethical conduct from those businesses with which we do business within our limited supply chain.
This statement is made regarding the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015 (the Act).
2. Document Definition & Coverage
This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).
In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with as a minimum.
3. Policy Statement
Modern Slavery & Human Trafficking
At Optima we have zero tolerance to slavery and human trafficking and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
This Anti-Slavery Policy Statement is the principal articulation of the Company’s policy on slavery and human trafficking. It is intended to inform and influence all the operational procedures within the Company.
Our stated Anti-Slavery Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure (amongst our other priorities) that slavery and human trafficking is not taking place anywhere in our business or related supply chains.
Optima Partners Limited will constantly uphold all laws relating to Modern Slavery and Human Trafficking in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the UK’s Modern Slavery Act 2015 (the Act), in regard to our conduct both at home and abroad.
4. Employee Responsibility
As an employee of Optima Partners Limited, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other information you are given.
All employees and those under our control are equally responsible for the prevention, detection, and reporting of modern slavery and human trafficking. They are required to avoid any activities that could lead to, or imply, a breach of this policy.
If you have reason to believe or suspect that an instance of modern slavery or human trafficking has occurred or will occur in the future that breaches this policy, you must notify the Chief Executive Officer.
If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Optima Partners Limited has the right to terminate a contractual relationship with an employee if they breach this policy.
5. How to Raise a Concern
If you suspect that there is an instance of modern slavery and/or human trafficking activities occurring in relation to Optima Partners Limited, you are encouraged to raise your concerns at as early a stage as possible. If you are uncertain about whether a certain action or behaviour can be the case, you should speak to your line manager and the Chief Executive Officer.
6. Training and Communication
Optima Partners Limited will provide training on this policy as part of the induction process for all new employees.
Optima Partners Limited will provide relevant training to employees etc. where we feel their knowledge of how to comply with the UK’s Modern Slavery Act 2015 (the Act) needs to be enhanced.
Optima Partners Limited’s policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.
7. Record Keeping
Optima will maintain a register of possible risks of modern slavery and human trafficking by its staff and associates (including agents, contractors, suppliers and intermediaries), as well as listing controls to mitigate those risks, and any actions required to improve these controls. The register will be regularly reviewed and updated, as and when required in relation to the nature of the specific risks.
Appropriate due diligence will be undertaken on both customers of and suppliers to Optima and its subsidiary companies. This due diligence will be proportionate to the level of perceived risk.
8. Monitoring and Reviewing
Optima Partners Limited’s Chief Executive Officer is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis and will assess its suitability, adequacy, and effectiveness.
Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Chief Executive Officer.
This policy does not form part of an employee’s contract of employment and Optima Partners Limited may amend it at any time so to improve its effectiveness.
