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Modern Slavery Policy

Issued January 1st 2021


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.

Gough & Co (Engineering) Ltd have a zero-tolerance approach to modern slavery and 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 in any of our supply chains.


Gough is 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. We expect the same high standards from any stakeholders, contractors, suppliers and other business partners, we work or are associated with. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. In short, should any supplier we work with be found to be breaching the Modern Slavery Act, we would cease operations with them as soon as practicably possible, pending a review.


The Policy

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

This policy does not form part of any employee’s contract of employment and we may amend it at any time. However, the policy is included in the Staff Handbook for staff information.

Responsibility for the Policy

The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Office Manager has primary and day-to-day responsibility for implementing this policy, monitoring its effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Compliance with the Policy

All employees, as well as any relevant stakeholders, must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. The Company expects its employees to make all reasonable efforts to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

Employees are encouraged to raise any concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. This should either be raised with the employee’s line manager or the Office Manager. If employees are in any doubt about whether an incident, the treatment of workers or any practices of suppliers, subcontractors or other bodies constitutes Modern Slavery, the issue should still be raised so it can be investigated, if required. Any issues raised will be kept in the strictest confidence by the Office Manager and Managing Director, in line with the company Whistle Blowing Policy.

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

Should any external party wish to make us aware of an issue, incident or situation, which may apply under this act, they should contact the Office Manager (Elizabeth Cole) – ercole@goughengineering.com

As stated above, we may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Communication and Awareness of this Policy

The Policy is communicated to all new staff starters, as part of their induction. As required, staff may be offered additional training in identifying possible situations where slavery may occur.

For transparency, the Group will publish their Modern Slavery Act 2015 Policy on their website for the public, consumers, employees, NGOs or investors to view. This policy is reviewed, at minimum, annually.