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Modern Slavery and Human Trafficking Policy Statement

Updated January 2024

Modern Slavery and Human Trafficking Policy Statement

  1. Policy Statement

Modern Slavery is an indefensible violation of basic human rights and esynergy recognizes we have a moral responsibility to prevent slavery and human trafficking in our business activities and to require our supply chain to do the same.

Modern Slavery takes various forms, such as slavery, servitude, forced and compulsory labour, child labour and human trafficking, all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

esynergy condemns all forms of modern slavery and will only seek to engage with reputable organisations that uphold the same values and are keen to work with our employees, partners, associates and end clients to do whatever we can to help eradicate this practice in the United Kingdom.

This policy applies to all persons:

  • working for esynergy or on our behalf, in any capacity, including employees at all levels, directors, officers, volunteers, interns and agents (‘Staff’); and;
  • our associates, external consultants, agencies, third-party representatives, and business partners (‘Suppliers’).

esynergy is committed to:

  • acting ethically and with integrity in all our business dealings and relationships;
  • implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains; and
  • ensuring there is transparency in our approach to tackling modern slavery in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.

Suppliers:        esynergy expects the same high standards from our Suppliers. As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our Suppliers will hold their own suppliers to the same high standards.

Regulations:   esynergy will always adhere to local and national laws and regulations designed to prevent Modern Slavery and expects the following principals to apply to all workers:

  • All workers must be free to terminate their employment upon reasonable notice;
  • No worker should be required to relinquish control or possession of their passports or other ID documentation in order to obtain employment;
  • No worker can be forced to work overtime or work any unpaid hours without their explicit consent;
  • All workers should enjoy freedom of movement and association;
  • All works must be free from the threat of violence or intimidation or discrimination in their working environments;
  1. Identifying Modern Slavery

There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support.  However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

  • The person is not in possession of their own passport, identification or travel documents.
  • The person is acting as though they are being instructed or coached by someone else.
  • The person allows others to speak for them when spoken to directly.
  • The person is dropped off and collected from work.
  • The person is withdrawn or appears frightened.
  • The person does not seem to be able to contact friends or family freely.
  • The person has limited social interaction or contact with people outside of their immediate environment.

The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.

  1. Responsibility for this Policy

The Board of esynergy Solutions Limited have overall responsibility for ensuring this policy complies with our legal and ethical obligations and all Staff members and Suppliers must comply with this policy.

  1. Reporting Modern Slavery

esynergy Staff and Suppliers are expected to report any incidence or suspicion of modern slavery or human trafficking they encounter at the earliest possible stage to a suitable senior staff member.    In the case of Staff this should be your line managers and Suppliers are advised to contact their esynergy Account Manager.

  1. Publication of the Policy

esynergy Modern Slavery and Human Trafficking Policy, together with other related policies such as Whistleblowing and Anti- Bribery, are included in our Employee Handbook and included in our induction training to reflect our commitment to acting ethically and with integrity in all our business relationships.

  1. Board Approval and Policy Reviews

This policy is made pursuant to section 54 of the Modern Slavery Act 2015 and has been approved by the Board of Directors, who will review and update it annually.


This policy has been approved by the Leadership Team and will be reviewed biannually to ensure the Company continues to promote and maintain the highest standards.

January 2024