Last Revised: 15th June 2019

Pure Developers is a division of Lacorta Resourcing Limited.

As an organisation, Pure Developers maintains relationships with many different organisations in its supply chain, as well as supplying varying levels of contract, interim, temporary and permanent workers. In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine what existing measures are undertaken and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or supply chain during the financial year ending 31st March 2019.

Pure Developers has adopted a statement of our corporate values on the prevention of modern slavery and human trafficking. This value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.

We expect all who have, or seek to have, a business relationship with Pure Developers and/or any member of our company, to familiarise themselves with and act at all times in a way which is consistent with our commitment to act ethically and with integrity.

PURE DEVELOPERS AND ANTI-SLAVERY

As part of our culture of good governance for good business, Pure Developers conducts our business in line with a set of core values which are reflected in our relationships with our customers, stakeholders, suppliers and team members.

All our business relationships, our processes and our procedures are built on foundations of ethics and integrity, which is reflected in our zero-tolerance approach to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015.

We are therefore committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings.

PURPOSE OF THIS POLICY

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which deprive an individual of their liberty as other persons exploit them for personal or commercial gain.

This document sets out the policy of Pure Developers (the “Company”) with the aim of the prevention of opportunities for people linked to our business to be treated as commodities, to occur within its businesses or supply chain. For the avoidance of doubt, this policy’s use of the term “modern slavery” has the same meaning given in the Act.

As a recruitment and staffing business operating in global markets, we recognise that we may have a greater responsibility than most to establish appropriate methods of assessing, preventing and mitigating risk of modern slavery occurring in their supply chains and organisation.

Pure Developers operates a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

STEPS FOR THE PREVENTION OF MODERN SLAVERY

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. However, we have a suite of Company policies that outline what is acceptable and expected in terms of behaviour in our Company, and all our employees are managed within these parameters.

This approach is reflected in the management of the supplier relationships too. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

RESPONSIBILITY FOR THE POLICY

Ultimate responsibility for the prevention and prevention of modern slavery rests with the Company’s leadership team. The Directors of the Company have overall responsibility for ensuring this policy and its implementation complies with our legal and ethical obligations.

SAFEGUARDS

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 are committed to ensuring 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 of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.

However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

REVIEW

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Directors on a regular basis and may be amended from time to time.