Anti-Slavery Policy

Spiritly Anti-Slavery Policy

Spiritly ("we", "us", or "our") is committed to ensuring that our operations and supply chains are free from any form of slavery, forced labour, and human trafficking. This Anti-Slavery Policy outlines the steps we take to comply with the UK Modern Slavery Act 2015 and to promote ethical and responsible business practices.

Scope
This policy applies to all employees, directors, officers, contractors, consultants, and any other individuals or entities working on behalf of Spiritly. We expect our suppliers, partners, and other third parties to share our commitment to preventing modern slavery and to implement similar policies and procedures within their own organisations.

Our Commitment

We are committed to:

a. Ensuring that no form of modern slavery, including forced labour or human trafficking, takes place within our organisation or supply chains.

b. Implementing and maintaining systems and controls to prevent modern slavery within our operations and supply chains.

c. Continuously assessing and mitigating the risk of modern slavery in our business and supply chains.

d. Encouraging and supporting our suppliers, partners, and other third parties to adopt similar measures in their own operations.

e. Providing appropriate training and guidance to our employees to raise awareness of modern slavery and its prevention.

Due Diligence and Risk Assessment

We will undertake due diligence and risk assessment procedures to identify, assess, and mitigate the risk of modern slavery within our operations and supply chains. These procedures may include, but are not limited to:

a. Identifying high-risk areas within our operations and supply chains.

b. Evaluating potential suppliers and partners based on their commitment to preventing modern slavery and their adherence to relevant laws and regulations.

c. Implementing contractual provisions requiring our suppliers and partners to comply with this policy and all applicable anti-slavery laws and regulations.

d. Conducting audits and inspections of our suppliers and partners to ensure their compliance with this policy and relevant laws.

Reporting and Remediation
We encourage our employees, suppliers, partners, and other stakeholders to report any concerns or suspicions of modern slavery within our operations or supply chains. Reports can be made confidentially and anonymously, and we will take all reasonable steps to protect the identity of the reporter.

If we become aware of any instances of modern slavery within our operations or supply chains, we will take appropriate action to remediate the issue, which may include terminating our relationship with the supplier or partner involved, reporting the issue to the relevant authorities, or implementing corrective measures to prevent future occurrences.

Training and Awareness

We will provide appropriate training and guidance to our employees, particularly those involved in procurement and supply chain management, to ensure they understand the risks of modern slavery and are equipped to identify and report any potential issues.

Monitoring and Review
We will regularly review and update this policy and our related procedures to ensure their continued effectiveness in preventing modern slavery within our operations and supply chains. We will also monitor our suppliers' and partners' compliance with this policy and take appropriate action if any instances of non-compliance are identified.

Communication
This policy will be made available to all employees, suppliers, and partners, and will be published on our website. We will communicate any changes or updates to this policy to relevant stakeholders in a timely manner.

Contact
If you have any questions or concerns about this Anti-Slavery Policy or our efforts to prevent modern slavery within our operations and supply chains, please contact us