Anti-Slavery and Human Trafficking Policy

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.

The common feature in all the above behaviours is the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 

2. As a responsible company, ESS Packaging Ltd is committed to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.

3. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with disclosure obligations we may have under applicable law. 

4. We expect the same standards from our contractors, suppliers, and other business partners. To that end we will, from the end of 2021, be making changes to our contracting processes. In particular, in future contracts, we will be including specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

Who Must Comply with this Policy?

  1. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Who is Responsible for this Policy?

  1. The company’s Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Operations Manager is responsible for day-to-day compliance, and any queries about this policy should be directed to him in the first instance.
  2. At an operational level this means that the Operations Manager is responsible for implementing this policy, monitoring its use and effectiveness, and reviewing internal control systems and procedures to ensure they are effective in countering modern slavery and human trafficking.
  3. In addition, the Operations Manager is responsible for ensuring those reporting to him understand and comply with this policy.
  4. This policy will be reviewed at least annually, and we may amend it at any time to update with acknowledged good practice.

Your Compliance with this Policy (Employees)

  1. You must ensure that you read, understand, and comply with this policy.
  2. Preventing, detecting, and reporting modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

How and When to Notify in Case of Non-Compliance

  1. If you believe or suspect that a breach of this policy has occurred, or may occur in the future, you must inform the Operations Manager as soon as possible.
  2. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.
  3. If you 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, you should raise it with the Operations Manager in the first instance.
  4. 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. We are committed to ensuring no one suffers any detrimental treatment (i.e., disciplinary action) 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.

Communication and Awareness of this Policy

  1. Training on this policy, and on the risk our business faces from modern slavery, forms part of the regular training for our employees.
  2. Our commitment to addressing issues of modern slavery in our business and supply chains will be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter (including the use of appropriate clauses in any formal contracts).

Breaches of this Policy

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


This policy has been approved by the company’s Managing Director.