Modern Slavery (Anti Slavery and Human Trafficking) policy

Last updated July 2023 Version 1


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 in order to exploit them for personal or commercial gain.

Vala has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implement and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, in our supply chain or within the Vala Portfolio of investee companies. Vala  is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and business partners.

Scope/to whom this policy applies

This policy applies to all persons working for Vala  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 Vala may amend it at any time. The Vala team are encouraged to familiarise themselves with the policy detailed below:

Whistleblowing policy

Vala has overall responsibility for ensuring this policy with senior management; and managers have day-to-day responsibility to ensure compliance with our legal and ethical obligation.  The Directors have 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.

Compliance with this policy

Vala employees and contractors must ensure that they read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Each individual is required to avoid any activity that might lead to, or suggest, a breach of this policy. Notification to the individual’s manager OR the Directors must be made as soon as possible if there is a belief or suspicion that a conflict with this policy has occurred, or may occur in the future. Each individual is encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If any employee believes or suspects a breach of this policy has occurred or that it may occur they must notify their manager or may report it in accordance with our Whistleblowing Policy as soon as possible. If they are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they should raise it with their line manager. We aim 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. Vala  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 own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform the manager immediately. If the matter is not remedied they should raise it formally using the Grievance Procedure which can be found in the Vala HR Portal.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, 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 of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Vala  may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.