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Compliance with this Keolis Amey Operations / Gweithrediadau Keolis Amey Limited (KAO), trading as Transport for Wales Rail Services, policy is mandatory through aligning KAO’s processes, people and behaviours to the commitments below.

Anti-slavery and human trafficking policy Modern Slavery and Human Trafficking.

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Policy Statement

This policy applies to all persons working for KAO or on KAO’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Keolis Amey Operations / Gweithrediadau Keolis Amey Limited (KAO), trading as Transport for Wales Rail Services ("we", "us" or "our") strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers and their supply chains, to engage in good employment practices and to comply with all relevant legislation and regulations in countries which they operate.

Commitments

01 As a company we expect that everyone working with us or on our behalf will support and uphold the following measures to safeguard against modern slavery:

02 We have a zero-toleration approach to modern slavery in our organisation and our supply chains.

03 The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

04 We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain. We have implemented this Anti-slavery Policy to monitor and reduce the risk of modern slavery occurring within our business or its supply chains.

05 In our efforts to monitor and reduce the risk of modern slavery occurring within our business and its supply chains we risk assess potential suppliers. If based on our risk assessment identify areas of potential suppliers that are at risk of modern slavery we take measures to address the risk, which may include: the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our service contracts with suppliers, requiring suppliers to comply with our Code of Conduct (the "Code") and minimum standards required to combat modern slavery and trafficking.

06 Consistent with our effort to reduce the risk of modern slavery with third parties we engage with we may require the following:

  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code
  • suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code

07 As part of our ongoing risk assessment and due diligence processes we may carry out audits of our suppliers to assess their compliance with our Code of Conduct.

08 If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

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