Anti-Slavery and Anti-Trafficking Policy
1. Introduction
Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking, where individuals are deprived of their freedom and exploited for commercial or personal gain, as set out in the Modern Slavery Act 2015.
Hot Yoga Nation Ltd is committed to a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically, responsibly and with integrity in all our business dealings, relationships and supply chains.
We expect the same high standards from all staff, teachers, contractors, suppliers and any other individuals or organisations we work with.
This policy applies to all employees, workers, teachers, consultants, contractors, suppliers and any other persons or organisations doing business with Hot Yoga Nation Ltd.
2. Our Commitment
Hot Yoga Nation Ltd recognises that modern slavery can occur in any business or supply chain, including through hidden or unknown subcontracting arrangements. Although we consider the risk of modern slavery to be low due to the nature and size of our business and supply chains, we take our responsibilities seriously.
Hot Yoga Nation Ltd is committed to:
- Preventing, detecting and reporting modern slavery in any part of our business or supply chains.
- Acting with integrity in all relationships with suppliers, contractors and service providers.
- Taking reasonable steps to ensure that those we work with share our commitment to preventing modern slavery and human trafficking.
- Encouraging staff, teachers and others connected with the business to raise concerns without fear of retaliation.
- Reviewing and improving our approach where appropriate as the business grows.
3. Responsibilities
The prevention, detection and reporting of modern slavery is the responsibility of everyone working for Hot Yoga Nation Ltd or on its behalf.
All staff, teachers, contractors and suppliers are expected to:
- Comply with this policy.
- Act ethically and responsibly.
- Report any concerns relating to modern slavery or human trafficking.
- Avoid engaging with any individual or organisation where there is a known or suspected risk of exploitation.
Management is responsible for ensuring that this policy is understood and followed, and for taking appropriate action where concerns are raised.
4. Due Diligence and Supply Chains
Hot Yoga Nation Ltd will take reasonable and proportionate steps to assess and manage modern slavery risks within its supply chains.
This may include considering:
- The nature of the goods or services being supplied.
- The country or sector from which goods or services are provided.
- The relationship with the supplier or contractor.
- Whether subcontractors are used.
- Any known risks within a particular industry or supply chain.
Where appropriate, Hot Yoga Nation Ltd may ask suppliers or contractors to confirm that they comply with the Modern Slavery Act 2015 and that their own operations and supply chains are free from slavery and human trafficking.
5. Raising Concerns
Hot Yoga Nation Ltd encourages anyone to raise concerns about modern slavery or human trafficking at the earliest possible stage.
Concerns may be raised with a member of the Hot Yoga Nation management team.
We will support anyone who raises a genuine concern in good faith, even if the concern later proves to be mistaken.
6. Suppliers and Contractors
Where appropriate, Hot Yoga Nation Ltd may include anti-slavery and anti-trafficking wording in supplier, contractor or procurement agreements.
Suppliers and contractors may be asked to warrant that:
- They comply with the Modern Slavery Act 2015.
- Their operations and supply chains are free from slavery and human trafficking.
- They will take reasonable steps to ensure that any subcontractors also comply with these obligations.
- Neither they nor, so far as they are aware, any of their officers, employees, subcontractors or associated persons have been convicted of any offence involving slavery or human trafficking.
Any breach of these obligations may result in Hot Yoga Nation Ltd terminating its relationship with the relevant supplier or contractor.
7. Training and Awareness
Hot Yoga Nation Ltd will provide guidance or training on modern slavery where appropriate, taking into account the size and nature of the business.
Staff and those working on behalf of the business should remain alert to the possibility of modern slavery and should raise any concerns with management.
8. Breaches of this Policy
Any breach of this policy may result in disciplinary action, termination of contracts or termination of the business relationship with the individual, supplier or organisation concerned.
9. Responsibility for this Policy
The Directors of Hot Yoga Nation Ltd have overall responsibility for this policy.
Day-to-day responsibility for implementing, monitoring and reviewing this policy rests with the management team.
This policy will be reviewed periodically and updated where necessary as the business develops.
10. Procurement Contract Wording
The following wording may be included in procurement contracts where Hot Yoga Nation Ltd receives goods or services:
“The Contractor acknowledges that, as an organisation carrying out business in the UK, it is required to comply with the Modern Slavery Act 2015. The Contractor warrants that it does so and will take reasonable steps to ensure that its operations and supply chains are free from slavery and human trafficking, including imposing substantially similar obligations on any subcontractors where subcontracting is permitted.
The Contractor further warrants that neither it nor any of its officers, employees, subcontractors or other persons associated with it, so far as it is aware, have been convicted of any offence involving slavery or human trafficking.
Any breach of this clause may be treated as a material breach of contract.”
11. Statement
Hot Yoga Nation Ltd is committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains. We will continue to act responsibly, review our approach and take appropriate steps to uphold ethical working practices.
