Policy Scope
This policy applies to all officers and employees of any National Express group company (whether in the UK, USA, Canada, Spain, Morocco, Germany or elsewhere). The National Express Group also expects its contractors, suppliers and other business partners to comply with this policy or a similar policy they have in place wherever possible.
Accordingly, all officers and employees of National Express group companies are expected to familiarise themselves, and comply, with this policy and to ensure, so far as possible, when they are dealing with contractors, suppliers and other business partners of the National Express Group, that they are also made aware of and comply with this policy or their own similar policy. This policy is supplementary to any and all National Express UK, US, Canadian, Spanish, Moroccan, German and other country local slavery and anti-trafficking policies (unless those policies are inconsistent with this Group policy, in which case this Group policy prevails).
Policy Purpose
It is National Express Group’s policy to conduct its business in an ethical manner and with integrity. Accordingly, National Express Group has a zero tolerance approach to modern slavery and this policy is intended to raise awareness of, and implement, that approach.
This policy covers modern slavery in the workplace and in any work-related setting outside the workplace e.g. business trips.
This policy will be reviewed and may be amended from time to time, as appropriate.
Legal Framework
This policy is non-contractual and may be amended by National Express Group plc from time to time.
Policy Statement / Procedure:
What is modern slavery?
Modern slavery takes various forms, including holding another person in slavery or servitude, requiring another person to perform forced or compulsory labour and arranging or facilitating the human trafficking of another person, all of which have in common the deprivation of a person’s liberty by another in order to exploit them. All forms of modern slavery are prohibited by this policy. Some practical examples of modern slavery are: (a) an employer confiscating a worker’s passport and/or official papers, which means the worker is unable to leave the country of the employer; (b) an employer forcing its workers to work by making threats such as physical harm to the workers themselves or their families or withholding wages from the workers. However, these examples are not exhaustive.
Therefore, care should be taken in any situation to determine whether a particular matter relating to workers, the treatment of workers more generally or their working conditions within our business or our supply chains constitutes modern slavery and would be prohibited by this policy. If there is any doubt about whether a situation or set of facts could constitute modern slavery, guidance should be sought as described below.
If you are in doubt, you should, in the first instance, raise this with your line manager and, if the line manager has any doubts, the line manager should seek guidance from a local Divisional Managing Director and HR Manager.
Why is compliance with this policy important?
Modern slavery is a criminal offence in the United Kingdom and in other countries in which the National Express Group operates. An individual who does something prohibited by this policy is therefore likely to commit a criminal offence and, if prosecuted, be subject to imprisonment and/or a fine.
Importantly, please also be aware that, if any officer or employee of any National Express Group company commits a modern slavery criminal offence, one or more National Express Group companies may also commit the same offence or a related offence and if such company is convicted of such offence, this would have a serious detrimental effect on the Group as whole. Clearly this would have a significant negative impact on its reputation. It may also prevent one or more National Express Group companies from participating in contract opportunities tendered by public authorities or utilities for periods of time, which in turn would have a serious negative impact on its business.
Any National Express Group officer or employee who breaches this policy is also likely to face disciplinary action, which could result in dismissal for misconduct.
What should I do if I am an officer or employee of a National Express Group company and I suspect modern slavery within the National Express Group’s business or supply chains?
If you have reasonable grounds to suspect that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains in breach of this policy, you are encouraged to report this as soon as possible to your line manager or to their line manager who, in turn, should report this matter to their local Divisional Managing Director and HR Manager.
If do not feel that you can report your reasonable suspicions in the manner described above, National Express Group operates a confidential “whistleblower’s” hotline which National Express Group officers and employees are encouraged to use. Please see the National Express Group’s Whistleblowing policy for further guidance on how to use the “whistleblower’s” hotline.
The National Express Group aims to treat all reports of suspected modern slavery seriously and sensitively. Reports to the “whistleblower’s” hotline are kept in confidence, subject to the need for the National Express Group to act responsibly and within the law. The National Express Group will accept reports made anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.
We encourage openness and will support anyone who raises a genuine concern about modern slavery in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicions. Any claims or allegations made which are found to be malicious or vexatious may result in disciplinary action being taken against the individual.
What should I do if I am a third party dealing with a National Express Group company and I suspect modern slavery within the National Express Group’s business or supply chains?
As noted above, the National Express Group aims to treat all reports of suspected modern slavery seriously and sensitively. The National Express Group therefore encourages any third party who is dealing with the National Express Group and who has a genuine concern about modern slavery in good faith to write, in confidence, to the Company Secretary or the Company’s Head of Internal Audit to raise their concern.
Roles and Responsibilities:
All those to whom this policy applies are required to familiarise themselves, and comply, with the terms of this policy.
Managers/supervisors at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
All officers and employees who deal with suppliers, contractors and business partners are also responsible for communicating this policy and seeking to ensure that those third parties also comply with this policy.
The board of directors of National Express Group plc has overall responsibility for ensuring compliance with our legal and ethical obligations.
Dean Finch
Group Chief Executive
10 May 2017