Anti-Slavery and Human Trafficking Policy


Modern slavery is the illegal exploitation of people for personal or commercial gain. Victims are controlled by force, threat, coercion, and deception. It can take various forms including trafficking of people, forced labour, sexual or criminal exploitation or domestic servitude.

Our global turnover is less than £36 million therefore whilst we are not compelled to publish a statement in accordance with the Modern Slavery Act, 2015 we believe our commitment to freedom and human rights is such that this is something we want to do.

Where there has been any above which operates in the United Kingdom to produce an annual statement. This should detail the steps taken during the financial year to ensure modern slavery isn’t taking place within any part of that organisation’s business or in its supply chain.

Our commitment:

Modern slavery is a criminal offence and a violation of fundamental human rights. Shackleton Consulting & Development Limited (trading as Shackleton Consulting Plus) has a zero-tolerance approach to Modern Slavery and is committed to preventing acts of slavery and human trafficking from occurring both within its business, the third parties and supply chain with which it operates.

It expects high standards from its contractors, suppliers, and other business partners and to doing business in a responsible and sustainable way.

Policy Scope:

This policy applies to all individuals working for the Company, including anyone providing services to the Company such as associates, consultants, or contractors.

Due to the nature of the business, the supply chains are primarily associated with the supply of software, software as a service-tools, travel, accommodation, subsistence expenses and consumables.  In the main these are sourced from low-risk countries for the purpose of modern slavery and human trafficking.

Policy Aim:

The aim of this policy is to help the Company act in accordance with the Modern Slavery Act 2015, to maintain the highest possible standards of business practice, and advise individuals and organisations with which it operates of the Company’s ‘zero-tolerance’ to slavery and human trafficking.

Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

The Law:

Modern slavery is a violation of an individual’s human rights.  Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015 (‘the Act’). The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the Company or under its control.

Policy Statement:

The Company takes its responsibilities to combat modern slavery seriously as demonstrated by the following measures:

  • The prevention, detection, and reporting of modern slavery in any part of its business or third parties, or supply chains is the responsibility of all those working for or with the Company or under its control.
  • All supply chain lines are continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.
  • The company will not knowingly support or deal with any business involved in slavery or human trafficking.
  • The company currently only has one employee (the Director) should the number of employees be expanded a regular audit and review of our practices will be conducted in order to check that all employees are paid at least the minimum wage and have the right to work.
  • The Company encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith.
  • The Anti-slavery and Anti-trafficking policy is published on our websites and
  • The Company will continue to develop its commitment to combat modern slavery and will provide staff training where appropriate.
  • This policy applies to all permanent and fixed-term staff employed by the Company, and any associates, contractors, consultants, or other persons acting under or on behalf of the Company.


Failing to observe this Company policy may lead to disciplinary action in accordance with the Company’s Disciplinary Policy or to the cancellation of current contracts, and decisions not to continue or commence any business relationships.

Monitoring Policy:

he policy will be monitored on an on-going basis to ensure that it addresses issues effectively.

The policy will be regularly reviewed by the Director to ensure its continuing suitability and relevance to the company activities.

The Company will ensure that all individuals working for or with the Company are advised of the policy; through it being publicised on the company website (consulting and training) / (mediation) or including in the contractual terms of engagement.

Reviewing Policy:

This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes.  Improvements will be made by learning from experience, benchmarking with similar organisations, and the use of an established annual review.

Policy Amendments:

Should any amendments, revisions, or updates be made to this policy it is the responsibility of the Company senior management to see that all relevant employees and related parties receive notice. Written notice and/or training should be considered.

Policy Implementation Notice:

This is the policy statement of Shackleton Consulting & Development Limited and the names under which the business trades. The overall and final responsibility for this policy and to ensure that this policy is put into practice is that of Russell Shackleton, Founder and Director.

Document History:

Policy Prepared By:Russell Shackleton
Policy Prepared Date:1st October 2023
Policy Version Number:V1.0
Next Policy Review Date:1st October 2024
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