Modern Slavery Policy

  • Document: Modern Slavery Policy
  • Owner: ISMS Lead, Starbuck & Associates Limited
  • Classification: Public
  • Published: 27 November 2024
  • Last reviewed: June 2026
  • Next review due: June 2027
  • Published source (master copy): starbuckassociates.com/modern-slavery-policy

This is a branded, controlled copy for the management system. The version published on the website is the master.

Modern Slavery Policy for Starbuck & Associates

At Starbuck & Associates, we are committed to ethical business practices and the prevention of modern slavery and human trafficking in all areas of our operations. We expect the same commitment from our clients, partners, suppliers, contractors, and associates, ensuring that our supply chains are free from any form of exploitation.

Purpose

This Modern Slavery Policy outlines our commitment to combating modern slavery, including forced labour, human trafficking, and exploitation, as defined under the Modern Slavery Act 2015. We believe in respecting human rights and treating everyone with dignity, and we hold our suppliers and associates to these same standards in all business interactions.

Our Expectations

We expect all clients, partners, suppliers, contractors, and associates working with Starbuck & Associates to ensure that their operations and supply chains are free from modern slavery. This includes:

  • Forced Labour: No individual should be forced to work against their will, through threat or coercion.
  • Human Trafficking: Suppliers and associates must ensure that no one is exploited through trafficking or deceptive recruitment practices.
  • Child Labour: We strictly prohibit the use of child labour in any part of our operations or supply chain.
  • Wage Exploitation: All workers should receive fair compensation and benefits in accordance with legal requirements, and they should not be deprived of their wages unlawfully.

Due Diligence and Risk Management

We conduct due diligence to ensure that our suppliers and associates are complying with this policy. This may involve:

  • Supplier Assessments: Conducting audits and assessments of suppliers’ compliance with our ethical standards.
  • Contractual Obligations: Including clauses in our agreements with suppliers that require adherence to anti-slavery measures and the right to terminate contracts if any violation occurs.
  • Training and Awareness: Ensuring that all relevant personnel within our supply chain are aware of the risks of modern slavery and how to identify and address them.

Reporting and Addressing Concerns

We expect our clients, partners, suppliers, contractors, and associates to promptly report any suspicion or evidence of modern slavery in their operations or supply chains. Reports can be made confidentially via our email: hello@starbuckassociates.com. All reports will be thoroughly investigated, and appropriate action will be taken to address any issues.

Consequences of Non-Compliance

Failure to comply with this policy may result in the termination of contracts and partnerships, as well as potential legal action. We take modern slavery very seriously and will not tolerate any form of exploitation within our business or from those we work with.

Commitment to a Slave-Free Supply Chain

Starbuck & Associates is committed to ensuring that modern slavery has no place in our business. We expect our clients, partners, suppliers, contractors, and associates to share this commitment and work proactively to ensure that slavery and human trafficking do not occur within their operations or supply chains.

By working with us, you agree to uphold this policy and support our efforts in promoting ethical and transparent business practices.

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