Anti-Slavery & Human Trafficking Policy

01. Our Commitment

At MacGregor Industrial Supplies (MIS), our people, our values and our communities matter. We are committed to doing the right thing and to operating responsibly, ethically and with integrity in everything we do.

We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to preventing modern slavery in our own operations and throughout our supply chains, and to working openly with colleagues, customers and suppliers to uphold the highest standards of ethical conduct.

This policy supports our People & Culture approach and reflects our values, particularly Do the Right Thing, Customer First and Community Spirit.

02. Purpose of This Policy

This policy sets out how MacGregor Industrial Supplies complies with section 54 of the Modern Slavery Act 2015 and outlines the responsibilities of colleagues, managers and the business in preventing modern slavery and human trafficking.

This policy underpins our annual Modern Slavery Statement, which is published on our website and reviewed annually.

03. Scope

This policy applies to:

• All colleagues, directors and agency workers
• All suppliers, contractors and business partners
• All areas of our business and supply chains

04. Our Business and Supply Chains

MacGregor Industrial Supplies is a supplier of industrial products and services across Scotland, working with a broad network of suppliers both in the UK and internationally.

Our supply chains include, but are not limited to:

• Manufacturing and distribution of goods
• Logistics and transport services
• Utilities and facilities services
• Professional and outsourced services

We recognise that some supply chains present a higher inherent risk than others and we are committed to identifying and managing these risks responsibly.

05. Policies and Governance

Our commitment to preventing modern slavery is supported by a range of People & Culture and governance policies, including:

• Code of Conduct
• Whistleblowing (Speak Up) Policy
• Equality, Diversity & Inclusion Policy
• Disciplinary Policy
• Right to Work and Immigration Compliance processes
• Health, Safety and Wellbeing policies

Together, these policies help create a safe, fair and respectful working environment for everyone connected to our business.

06. Due Diligence and Risk Management

We take a proactive, risk-based approach to preventing modern slavery. This includes:

• Identifying and assessing areas of potential risk within our supply chains
• Using supplier questionnaires and onboarding checks to assess ethical standards
• Including modern slavery expectations within supplier agreements where appropriate
• Working with suppliers to support improvement where issues are identified
• Monitoring and reviewing supplier compliance on an ongoing basis

Any concerns or instances of non-compliance are assessed on a case-by-case basis, with appropriate and proportionate action taken.

07. Reporting Concerns

08. Training and Awareness

We are committed to raising awareness of modern slavery and human trafficking.

Training and guidance will be provided to colleagues where appropriate, particularly those involved in recruitment, procurement and supplier management, to help them identify risks and understand their responsibilities.

09. Roles and Responsibilities

• The Board and Senior Leadership Team have overall responsibility for ensuring compliance with the Modern Slavery Act.
• The People Team is responsible for maintaining this policy, supporting colleagues and coordinating reporting and training.
• Managers are responsible for promoting ethical practices and raising concerns.
• All colleagues are expected to act in line with this policy and our values.

10. Review

This policy will be reviewed annually and updated as required to ensure it remains effective, proportionate and aligned with best practice.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Directors.