Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we’re committed to acting ethically and with integrity in all our business dealings and relationships, and to implement and enforce effective systems and controls to make sure modern slavery isn’t taking place anywhere in our own business or our supply chain.

We’re also committed to making sure there’s transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we may include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, +people partners, officers, agency workers, agents, contractors, external consultants, third-party representatives and business partners.

Organisational structure and supply chains 

This statement covers the business activities of Setters which are as follows: 

· Safety Culture Development Programmes 

· Safety Consultancy 

· Training 

The Company currently operates in the following territories/countries: 

· UK 

· Europe 

· Worldwide 

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships. 

Due Diligence 

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners. 

Compliance with the Policy

You must make sure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You’re required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify the HR and finance department as soon as possible, if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You’re encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify or report it as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with the HR and finance department.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We’re committed to making sure no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you’ve suffered any such treatment, you should inform immediately.


Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee or +people partner 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 organisations working on our behalf if they breach this policy.

This Modern Slavery and Human Trafficking Policy Statement will be regularly reviewed and updated as necessary