THE PURE GOLD COMPANY
TPGC – Modern Slavery Policy – 2025
- Overview and how we define Modern Slavery
1.1. Slavery, forced labour, servitude, and human trafficking are types of ‘Modern Slavery’ – criminal activity that deprives victims of their liberty and usually involves financial and other exploitation.
1.2. This policy is aligned with the Modern Slavery Act 2015, which applies to all commercial organisations carrying on a business, or part of a business, in the UK, regardless of where they are incorporated.
1.3. We conduct our business fairly, ethically and with respect to fundamental human rights. We are committed to the prevention of all forms of Modern Slavery, both in our business and in our supply chains. We will not tolerate it.
1.4. You must read and comply with this policy if you work for, or on behalf of us in any capacity including as: an employee, director, officer, worker, consultant, volunteer, supplier or service provider.
1.5. Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and us. It could also involve other legal steps being taken against you.
1.6. Our Anti-Slavery Officer (‘ASO’) is Josh Grey, Head of People & Culture. The ASO is responsible for overseeing due diligence procedures, coordinating investigations, and reporting concerns to senior leadership.
1.7. If you are an employee, this policy does not form part of your employment contract, and we may update it at any time.
1.8. The Pure Gold Company is a bullion brokerage based in London, employing approximately 30 employees. We procure services including secure storage, logistics, and professional services. We expect transparency from our suppliers to mitigate any potential risks associated with modern slavery. - Preventing Modern Slavery in our business
2.1. We carry out appropriate checks on all employees, recruitment agencies and suppliers, so that we know who is working for us or on our behalf. Checks include verifying the identity and right to work of all employees, and conducting ethical audits or supplier declarations where appropriate.
2.2. We give every employee a written employment contract, and he or she is paid in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks and holidays. We prohibit the use of recruitment fees being charged to workers by third parties. - If you are one of our Suppliers
3.1. We may require contractual assurances that you and your supply chain meet our anti slavery standards and that you allow us to audit compliance. If you supply us with goods or services, you must assess your business and supply chains and confirm to our ASO that you:
3.1.1. comply with your legal obligations, in relation to Modern Slavery; and
3.1.2. are committed to ensuring there is no Modern Slavery taking place in your business, or in any of your supply chains.
3.2. You may be asked to provide a copy of your anti-slavery policy.
3.3. You must conduct due diligence on your own supply chain and take reasonable steps to prevent modern slavery. This includes risk assessments, monitoring, and maintaining contractual standards with your suppliers and subcontractors.|
3.4. We reserve the right to take immediate action, including suspension of services, contract termination, or legal proceedings, where there is a breach of this policy. - If you are an Employee or a Worker providing services for us
4.1. You must immediately report any suspicions of Modern Slavery in our business or supply chains to our ASO. Our ASO will investigate and report to our CEO within a reasonable time, on actions which may require to be taken. This includes concerns such as workers showing signs of control, excessive working hours, withholding of passports, or unsuitable living conditions.
4.2. Relevant staff, particularly those involved in procurement, recruitment or supplier management, will receive training on this policy and how to identify potential signs of modern slavery.
4.3. You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately tell our ASO and, if you are an employee, refer to our Grievance and Whistleblowing Policies. All reports will be handled confidentially in accordance with our Whistleblowing Policy. - Monitoring and Review
5.1. We regularly assess the risks of modern slavery within our operations and supply chains. Risk assessments are conducted annually or whenever new suppliers are onboarded, focusing on sectors, geographic locations, and specific services or goods known for higher risks. If heightened risks are identified, we implement specific mitigation measures such as enhanced supplier scrutiny, contractual safeguards, and additional auditing.
5.2. To measure the effectiveness of our anti-slavery actions, we monitor and report on the following Key Performance Indicators annually:
5.2.1. Percentage of employees trained on identifying and reporting modern slavery.
5.2.2. Number of supplier audits conducted.
5.2.3. Number of modern slavery concerns raised and resolved.
5.2.4. Percentage of suppliers who provided compliance statements or policies affirming their anti-slavery
practices
5.3. We will review this policy annually or when there is a significant change in the law, our operations, or supply chain risk. If required under the Modern Slavery Act 2015, we will also publish an annual modern slavery statement.
5.4. Responsibility for ensuring this policy’s effectiveness lies with the Directors. If legally required, our annual statement will detail the steps taken during the year to prevent modern slavery in our operations and supply chains. - Supporting policies
6.1. This policy should be read in conjunction with our Whistleblowing, Recruitment, and Code of Conduct policies. - Approval
7.1. This policy has been reviewed, approved, and endorsed by the Directors, underscoring our ongoing commitment to preventing modern slavery and human trafficking in our business and supply chains.
7.2. This policy is reviewed annually and updated as necessary to ensure compliance with the Modern Slavery Act 2015.
Signed by the Director:
Joshua Saul, CEO
1st April 2025