Modern Slavery Policy

1. Introduction

Esco is committed to preventing modern slavery and human trafficking in all its forms. This policy sets out our commitment to ensuring that slavery, servitude, forced labour, and human trafficking (referred to collectively as "modern slavery") do not occur within our organization or in any of our supply chains. The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business operations, and we expect the same from our employees, suppliers, and business partners.

This policy applies to all persons working for us 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 we may amend it at any time.

2. Scope

This policy applies to all employees, contractors, suppliers, and other business partners associated with Esco. It covers all activities and processes carried out within our organization and extends to our supply chains, including both domestic and international operations.

3. Compliance

Esco is committed to complying with all applicable laws and regulations related to modern slavery. This includes but is not limited to the Modern Slavery Act 2015 (or relevant legislation in the respective jurisdiction).

4. Responsibilities

4.1 The Company

The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2 Primary Responsibility

The Company 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.

4.3 Management Responsibilities

The management of Esco is responsible for ensuring that this policy is effectively implemented, maintained, and communicated throughout the organization. They are accountable for monitoring compliance with this policy and appropriately addressing any violations or breaches.

4.4 Employee Responsibilities

All employees are expected to familiarize themselves with this policy and act in accordance with its principles. Employees are encouraged to report any concerns or suspicions of modern slavery promptly using the channels provided by the organization.

5. Supplier Engagement

We will work closely with our suppliers and business partners to promote ethical and responsible practices. We expect our suppliers to adhere to the same high standards we set for ourselves regarding modern slavery prevention. We may terminate relationships with suppliers who fail to comply with this policy or refuse to improve their practices.

6. Training and Awareness

Esco is committed to raising awareness and understanding of modern slavery among our employees. We will provide relevant training programs to ensure that our employees can identify the signs of modern slavery and understand the appropriate actions to take.

7. Reporting and Whistleblowing

We encourage all employees, contractors, and stakeholders to report any concerns or suspicions of modern slavery promptly and without fear of reprisals. We will ensure that all reports are treated confidentially and that appropriate investigations are conducted. Esco will take appropriate action against any individuals found to be involved in modern slavery.

8. Continuous Improvement

We will regularly review and update this policy to reflect changes in legislation, best practices, and the evolving nature of modern slavery risks. We are committed to continuously improving our processes and procedures to combat modern slavery effectively.

9. Communication and Review

This policy will be communicated to all employees, suppliers, and business partners. It will be made available on our website, and employees will receive copies. This policy will be reviewed periodically to ensure its ongoing relevance and effectiveness.