1. Policy Statement 

1.1 This policy is a statement of principles outlining Mary’s Meals’ commitment to preventing modern slavery in our organisation. The Mary’s Meals aspiration is that all network entities implement local policies and processes to achieve this in line with local laws, regulations and guidance. 

1.2 The Modern Slavery policy aligns with other global policies including Whistleblowing, Safeguarding, Protection of Funds and Anti Bribery & Corruption. 

1.3 Mary’s Meals strictly prohibits the use of modern slavery and human trafficking in our operations. We are committed to acting ethically and with integrity in all our operations and to implementing effective procedures, systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We hold our suppliers, partners and contractors to the same high standards. 

2. Purpose 

2.1 The purpose of this document is to: 

• Outline Mary’s Meals’ zero tolerance approach to modern slavery.
• Define the forms that modern slavery can take set out responsibility for reporting.
• Set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery.
• Provide information and guidance to those working for and on Mary’s Meals behalf on how to recognise modern slavery. 

3. Scope / Applicability 

3.1. This policy applies to MMI, National Affiliates and Programme Affiliates. It applies to all employees, directors, volunteers of the same We expect partners, partnering agencies, consultants, contractors, suppliers and to any other people or bodies associated with Mary’s Meals, within all regions to adhere to similar high standards around modern slavery, although this policy does not strictly apply to them... 

3.2. Mary’s Meals expects external parties such as suppliers, partners and contractors to adhere to the general principles of this policy but also to have or put in place similar policies and procedures if possible. In any event, arrangements with programme partner organisations are subject to clear contractual terms, including specific provisions that require the partner organisation to comply with minimum standards and procedures relating to modern slavery. 

4. Definitions 

4.1. 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 of children or adults, 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.

5. Actions 

5.1. As part of Mary’s Meals initiative to identify and mitigate risk we:

• Carry out due diligence checks on partner organisations and have a robust procurement manual that sets out requirements for buying goods and services.
• Build long-standing relationships with local suppliers and make clear our expectations of business behaviour.
• Have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
• Encourage training is provided to relevant staff or volunteers to ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and supply chains. 

6. Roles and Responsibilities 

6.1. The MMI Board and each affiliate Board (subject to the terms of their Scheme of Delegation) have overall responsibility for ensuring this policy, and all local policies and procedures flowing from this, comply with all local legal and ethical obligations, and that all those under the scope comply with it. 

6.2 Each Mary’s Meals entity should put in place suitable arrangements for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

6.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and those policies and procedures flowing from this. 

7. Reporting and accountability 

7.1 The prevention, detection and reporting of modern slavery in any part of the Mary’s Meals network or supply chains is the responsibility of all staff and volunteers. Any activity that might lead to, or suggest, a breach of this policy must be avoided. 

7.2 The Global Whistleblowing Statement will be of relevance where there are any concerns or suspicions of modern slavery in any part of the organisation, and any such concerns should be reported in line with the relevant whistleblowing procedure, or other relevant local reporting processes as soon as possible. 

7.3 All Mary’s Meals entities reserve the right to terminate their relationship with third parties if there has been a breach of this policy. 

8. Local policies and procedures 

8.1 All Mary’s Meals entities must ensure that this policy has been read, understood, and complied with, and commit to creating and implementing local policies and processes to support the principles outlined in this policy, which should be acknowledged by all. 

8.2 All Mary’s Meals entities are encouraged to provide training to all relevant staff or volunteers on local policies flowing from this, and to ensure a high level of understanding of the need for checks to prevent modern slavery. 

8.3 Breaches of this policy, or any local policies and procedures, should be taken seriously and dealt with appropriately by the relevant Mary’s Meals entity.