Updated 20 June 2023

Modern Slavery and Human Trafficking Policy

Purpose
The Modern Slavery and Human Trafficking Act 2015 does not directly apply to IPEX due to the nature and size of business. However, we actively take actions to abide by this legislation due to our client requirements and perform checks to ensure all our suppliers also comply. This policy sets down:
  • IPEX Consulting’s commitment to preventing slavery and human trafficking in our business activities.
  • The steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains.
  • IPEX policy and minimum requirements to adhere to this legislation.
IPEX is committed to identify, prevent and mitigate adverse Modern Slavery and Human trafficking impacts which are caused or influenced by business activities before they occur.

Organisational structure and supply chains

IPEX specialises in enabling and improving rail operations and projects, particularly in rolling stock operational and commercial engineering. Our supply chain is formed of Associates, UK based small independent companies. We operate in the UK and on an international basis.

The following is the process by which the Company assesses whether activities or countries are high risk in relation to modern slavery or human trafficking.

High Risk Activities

IPEX does not consider any of its activities at high risk of Modern Slavery and Human Trafficking, is due to the nature of the services it provides:
  • IPEX provides high level strategic railway consultancy services
  • It is limited to professional services.
  • IPEX operates primarily in the UK, Australia and New Zealand.
If the nature of IPEX’s service changes this policy will be reviewed and reevaluated whether our activities are high risk or not.

Responsibility

Responsibilities for the Company’s anti-slavery initiatives is as follows:
  • Policies: The Operations Director is responsible for creating and reviewing policies. In the process, this document will be reviewed should the legislation, other requirements or business needs change. This document is to be reviewed at minimum intervals of 3 years. The document will be reissued after every scheduled review with changes made noted in the Amendment Record above.
  • Risk assessments: Operations Director is responsible for carrying out a risk assessment at the beginning of every project to ensure its compliance with various legislations including Modern Slavery and Human Trafficking Act.
  • Due diligence: Operations Director ensures the due diligence in respect of known or suspected instances of modern slavery and human trafficking.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, all the new starters are informed about this policy. As an when changes are made to the policy, all employees are briefed to ensure up-to-date understanding.

Related Policies

The Company is committed to ensuring that there is no slavery or human trafficking in our business or our supply chains as well as acting ethically in our business relationships. The following policies relate to this:
  • Whistleblowing policy
  • IPEX Code of Conduct
  • Environmental Policy
  • Human Rights and Fair Labour Policy
  • Anti-Discrimination and Equal Rights Policy

Copies of our policies are available to clients and stakeholders on request.

Due Diligence Processes for Slavery and Human Trafficking

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
  • Consider the modern slavery and human trafficking risks of each new supplier
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

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Established in 2003, IPEX has a wide client and project base in global rail and transport consultancy. Our team has a combined wisdom of over 200 years’ working with major blue chip rail organisations, covering all aspects of rail operations, maintenance, and projects. Talk to us today and see how we can help you.

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Address

IPEX Consulting
Liberty House
222 Regent Street
London
W1B 5TR

Contact
+44 (0) 203 642 5893
moc.gnitlusnocxepi@ofni
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