Modern Slavery and Human Trafficking


Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

Zeetta has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the organisation.

Zeetta is committed to ensuring there is transparency in its organisation and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015.

Zeetta expects the same high standards from all of its contractors, suppliers and other business partners, and as part of its contracting processes. Zeetta includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children and expects that suppliers will hold their suppliers to the same high standards.

This policy applies to all persons working for Zeetta or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and it may be amended at any time.

Responsibility for the policy

The Zeetta board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those in our organisation comply with it.

The Zeetta Chief Executive Officer (CEO) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

In conjunction with Human Resources (HR), Line Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issue of modern slavery.

Compliance with the policy

Employees must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chains is the responsibility of all those working for us. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees must notify their line manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or of any supplier at the earliest possible stage.

If an employee believes or suspects a breach of this policy has occurred or that it may occur, they must notify their manager or HR.

If an employee is unsure about whether a particular act constitutes any of the various forms of modern slavery, they should raise it with their manager or HR.

Zeetta aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Zeetta is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our organisation or with any of our suppliers. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Communication and awareness of this policy

Training on this policy, and the risks, our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Zeetta may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

ZN-011-01-19 Modern Slavery and Human Trafficking Policy