Modern Slavery And Human Trafficking Policy

  1. Scope

    This policy applies to all stakeholders, including all persons working for or on behalf of the Reply Group in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

    This policy does not form part of any employee’s contract of employment and may be amended at any time.

    This policy should be read in conjunction with Reply’s Code of Ethics and Whistleblowing Policy.

  2. Anti-Slavery and Human Trafficking Policy

    Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty for personal or commercial gain.

    The Reply Group is committed to acting ethically and with integrity in all business dealings and relationships. It implements and enforces effective systems and controls to ensure that modern slavery is not taking place anywhere in its business or supply chains.

    The Reply Group is also committed to transparency in its business, consistent with its disclosure obligations under the Modern Slavery Act 2015.

    The Group expects the same high standards from all contractors, suppliers, and business partners. It seeks to include contractual provisions requiring compliance with this policy and will cease relationships with parties who fail to meet these standards.

  3. Responsibility for the Policy

    The Board of Reply Limited has overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under its control across the UK Reply business comply with it.

    The UK COO has primary responsibility for implementing this policy across the UK business. On behalf of the UK COO, the UK Compliance function monitors its use and effectiveness, handles queries, and reviews internal systems and procedures to ensure they are effective in countering modern slavery.

    Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy, including the reporting obligations, and receive appropriate training where necessary.

    Partners (including Executive Partners) are responsible for ensuring compliance within their respective companies and operations. This includes ensuring that client contracts do not tolerate, ignore, or directly or indirectly support modern slavery.

  4. Compliance with the Policy

    The prevention, detection, and reporting of modern slavery in any part of the business or supply chains is the responsibility of all stakeholders working for or under the control of the Reply Group.

    All stakeholders must avoid any activity that might lead to a breach of this policy and must notify their manager or relevant contact as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur.

    Stakeholders are encouraged to raise concerns about any issue or suspicion of modern slavery at the earliest possible stage, including where they are unsure.

    The Reply Group promotes openness and will support anyone who raises genuine concerns in good faith. No individual will suffer detrimental treatment (including dismissal, disciplinary action, or threats) as a result of reporting concerns.

  5. Communications

    This policy is published on Reply’s internal platform and must be read and accepted by all employees.

    Training on this policy may form part of the induction process where deemed appropriate.

    The Group’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of the relationship and reinforced as appropriate. Records of such communication must be maintained.

    Those responsible for entering into contracts must take reasonable steps to ensure appropriate provisions are included within contractual documentation.

  6. Breaches of This Policy


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

    The Reply Group may terminate its relationship with any individual or organisation working on its behalf if they fail to comply with this policy or their contractual obligations relating to modern slavery.