Principles
- Every employee should have freedom of movement. The ability of employees to move freely should not be restricted by their employer through abuse, threats or practices such as unlawful retention of passports and valuable possessions.
- Employees should not be imprisoned, bonded, indentured, slaved, trafficked or forced to undertake compulsory labour in any form, including forced overtime. All work must be carried out voluntarily and without harsh or inhumane treatment, including but not limited to physical punishment, physical, psychological or sexual violence or coercion, verbal abuse, harassment or intimidation.
- No employee should pay for a job. Fees and costs associated with recruitment and obtaining employment should not be paid by employees.
- No employee should be indebted or coerced to work (whether physically or mentally). Employees should work voluntarily, be informed of their employment terms and conditions in advance without misrepresentation and paid regularly, as agreed and in accordance with any applicable laws and regulations.
- Working hours and any overtime worked should comply with national laws and/or collective agreements.
- There should be no use of child labour. Nobody should be employed under the minimum age. Subject to the overriding prohibition on the use of child labour, if employees under the age of 18 are employed then particular care should be taken as to the duties that they carry out and the conditions in which they are required to work to ensure that they come to no physical, mental or other harm as a direct or indirect result of their work or working conditions.
- Migrant employees, their families and those closely associated with them should not be subject to discrimination due to their nationality.
- Housing, where provided, should be clean, safe, and meet the basic needs of the employee.
- Employees should be free to file grievances to their employers about the employer’s treatment of them and workers shall not suffer detriment, retaliation, or victimization for having raised a grievance.
Compliance with this Policy
Everyone subject to this Policy should take such steps as are reasonable and proportionate, having regard to the nature of their business and the industry in which they operate, to identify potential high and medium risks of modern slavery in their supply chains. To the extent it is commercially practicable, they should use their buying power to influence their own supply chains from such prohibited activities.
Brainnwave expects its business partners throughout its supply chain to support the principles contained in the Policy and to actively communicate and promote the principles to their own supply chains. We reserve the right to request details of how they and their supply chains comply with this Policy and to take action where appropriate, including termination of the business relationship.
Reporting of breaches
Any person concerned about a breach of this Policy may report their concerns via our website and ask for their concerns to be treated on a confidential basis and forwarded to our Legal team.
Individuals with concerns are encouraged to provide their name and contact details so that the issues that they raise can be investigated thoroughly. However, we recognize that in some circumstances an individual will only be prepared to raise their concerns on an anonymous basis, and we commit to investigate anonymous allegations as thoroughly as possible and to take the necessary remedial action.
