1. Policy Statement

Dragonfly Leisure is committed to preventing modern slavery, servitude, forced labour, and human trafficking in all aspects of its activities and supply chains. We recognise our responsibility to act ethically, with integrity and transparency in all business relationships, and to implement effective systems and controls to safeguard against modern slavery.
Dragonfly Leisure has a zero-tolerance approach to modern slavery and is committed to ensuring that there is no modern slavery or human trafficking within our organisation or supply chains.

2. Purpose

The purpose of this policy is to:
• Demonstrate commitment to combating modern slavery and human trafficking.
• Ensure compliance with the Modern Slavery Act 2015.
• Provide guidance to employees, trustees, volunteers, contractors, and suppliers on recognising and reporting concerns.
• Promote ethical and responsible procurement practices.

3. Scope

This policy applies to:
• Trustees
• Employees
• Volunteers
• Contractors and consultants
• Suppliers, service providers, and business partners
All individuals associated with Dragonfly Leisure are expected to uphold the principles set out in this policy.

4. Responsibilities

Trustees
The Board of Trustees has overall responsibility for ensuring that this policy complies with legal and ethical obligations and that adequate resources are available for its effective implementation.
Senior Management
Senior leaders are responsible for:
• Implementing and monitoring this policy.
• Ensuring staff are aware of their responsibilities.
• Taking appropriate action where concerns are identified.
Employees and Volunteers
All staff and volunteers must:
• Read and understand this policy.
• Remain vigilant to signs of modern slavery and exploitation.
• Report concerns promptly through the appropriate channels.

5. Our Commitments

Dragonfly Leisure will:
• Conduct its activities in accordance with UK legislation and best practice.
• Seek to work only with organisations that demonstrate ethical employment practices.
• Include modern slavery considerations within procurement and supplier selection processes.
• Investigate concerns appropriately and confidentially.
• Protect whistleblowers and individuals who raise genuine concerns.
• Promote awareness of modern slavery risks amongst staff and volunteers.

6. Supply Chain Expectations

Dragonfly Leisure expects all suppliers and contractors to:
• Comply with the Modern Slavery Act 2015.
• Operate lawful and ethical recruitment practices.
• Ensure workers are employed voluntarily and are free to leave employment.
• Pay employees fairly and in accordance with applicable laws.
• Provide safe and healthy working conditions.
• Ensure there is no use of forced, bonded, trafficked or child labour.
Where concerns arise regarding a supplier’s practices, Dragonfly Leisure reserves the right to investigate and take appropriate action, including termination of contracts if necessary.

7. Identifying Modern Slavery

Indicators of modern slavery may include:
• Individuals appearing fearful, withdrawn or controlled.
• Restrictions on a person’s movement or communication.
• Signs of physical abuse, neglect or poor living conditions.
• Workers lacking control over their own identification documents.
• Excessive working hours or unpaid work.
• Evidence of debt bondage or coercion.
These indicators do not necessarily mean modern slavery is occurring but should prompt further consideration and reporting.

8. Reporting Concerns

Anyone who suspects modern slavery or human trafficking should report their concerns immediately to:
• Designated Safeguarding Lead
• Concerns will be handled sensitively and investigated appropriately.
• If there is an immediate risk of harm, concerns should be reported to the police by calling 999.

Additional reporting can be made to:
Modern Slavery and Exploitation Helpline
08000 121 700
www.modernslaveryhelpline.org

9. Training and Awareness

Dragonfly Leisure will promote awareness of modern slavery through:
• Staff induction processes.
• Relevant safeguarding training.
• Procurement and contract management procedures.
• Periodic policy reviews and communications.

10. Monitoring and Review

Dragonfly Leisure will review this policy annually or sooner where there are significant changes in legislation, organisational structure, or identified risks.