Modern Slavery Policy

Policy Statement

Spicy Minds Ltd (Trading as Rowan) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers, contractors, and other business partners.

Scope of Policy

This policy applies to all persons working for or on behalf of Spicy Minds Ltd, in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and any other third-party representatives (Collectively referred to as employees).

Responsibilities

Directors: Responsible for policy implementation and ensuring staff understand and comply with it.

Staff: Must alert directors immediately of any concerns about modern slavery in any parts of our business.

Compliance

Employees must read, understand, and comply with this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or on our behalf.

Avoidance of compliance will be treated as a serious matter and may result in disciplinary action.

Risk Assessment

Regularly reviewing supply chains, assessing and mitigating risks of modern slavery and human trafficking.

Due Diligence

Undertaking appropriate due diligence when engaging suppliers, and reviewing their practices and supply chains.

Training

Providing necessary training to staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and business.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

Review

This policy will be reviewed and updated regularly to reflect new legal and regulatory developments and ensure good practice.

Date of Last Review: 18 Jan 2024