Virtual Lease Services (VLS) has a zero-tolerance approach to Modern Slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure Modern Slavery is not taking place in our own business or supply chain.

We are committed to ensuring that our business is transparent, as such we will comply with the disclosure obligations under the Modern Slavery Act 2015.

VLS expects our contractors, suppliers and other business partners to uphold high standards in all business practices: as part if their contracting processes, we include prohibitions against the use of staff sourced from force, compulsory or trafficked labour, anyone held in slavery or servitude. VLS expects their suppliers to hold these high standards.

VLS Board has overall responsibility for ensuring that this policy complies with VLS’ legal and ethical obligations and that all those under their control comply with it.

Management at all levels in VLS are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on Modern Slavery.

Employees will have access to this policy via People HR.

All VLS employees are responsible for the prevention, detection and reporting of Modern Slavery in any part of our business or supply chains. Employees are required to avoid any activity that may lead to a breach of this policy and the Modern Slavery Act 2015.

Employees must notify their Manager as soon as possible if they believe or suspect that, a conflict with, or suspect a breach of this policy has occurred, or may occur, in the future. Employees can also report any breach by following our whistleblowing policy.
Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of our business or supply chains at the earliest possible stage.

If an employee is unsure whether an act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any, or all, the various forms of Modern Slavery.

This policy is available to all staff and is published on our website.

As part of the induction process, employees are advised on the policy including who to report it to. Recruiting Officers are asked to refer to this policy when making recruitment decisions.

Our zero-tolerance approach to Modern Slavery is communicated to all suppliers, contractors and business partners at the outset of our relationship with them. Suppliers are asked to comply with our Anti-Slavery and Human Trafficking policy from the onset of the relationship. Suppliers who are unwilling to comply will not be onboarded.

The Senior Management will annually review this compliance with this policy in terms of reporting requirements.

Any employee who breaches this policy will face disciplinary action. This could result in action up to dismissal in accordance with VLS policies. We may terminate our relationship with other employees, suppliers and any other associates working with VLS if they breach this policy.

As part of our initiative to identify and mitigate risk we have in place systems to:

  • Identify and assess potential risk areas in our supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and;
  • Protect whistle-blowers.

We use the following key performance indicators (KPI’s) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our organisation or supply chains:

  • Recording and monitoring any incidents or reports made to us by staff in accordance with our Anti-Slavery policy using the mechanisms established in our confidential reporting procedures;
  • Monitoring any incidents or allegations across our supply chains which conflict with our values; and
  • Recording any incidents or complaints received from any third parties concerning slavery and human trafficking