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Ethical & Anti-Slavery Policy


This policy is applicable to employees of Starlizard, Star Lizard (Ireland), Lacerta, Jamestown Analytics, Lizard Ventures, Bloom Foundation and Blue and White Capital. It does not form part of the employment contract and may be amended at our discretion from time to time. This policy applies to all employees and contractors, including full-time, part-time, fixed-term, and temporary workers.

Corporate Social Responsibility (CSR) at the company encompasses our commitment to operate in an economically and environmentally sustainable manner, while acknowledging the interests of all our stakeholders.  We conduct our business according to standards of good ethical, employment and environmental practice.

We expect our suppliers to operate on the same principles and in any other areas notified by us from time to time.

Child Labour

We will not engage in or support the use of child labour. Suppliers shall not engage in child labour.

In the event of a breach of this requirement, we will participate in and contribute to programmes that provide for the transition of any child found to be performing child labour. This will enable him or her to attend and remain in quality education until no longer a child.

Forced Labour

There is no forced, bonded or involuntary prison labour. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

We will not engage in or support the use of forced or compulsory labour, nor will personnel be required to pay deposits or lodge identification papers with the company upon commencing employment.

Neither us nor any entity supplying labour to us shall engage in or support trafficking in human beings.

Health and Safety

We will provide a safe and healthy work environment in accordance with the terms of our Health and Safety Policy.

Freedom of Association and Right to Collective Bargaining

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

We have an open attitude towards the activities of trade unions and their organisational activities.

Workers’ representatives shall not be discriminated against and have access to carry out their representative functions in the workplace.


There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.


No corporal punishment, mental or physical coercion or verbal abuse.

No harsh or inhumane treatment is allowed. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Working Hours

Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.


We will respect the right of personnel to a living wage and ensure that wages paid for a normal work week shall always meet at least legal or industry minimum standards and shall be sufficient to meet the basic needs of personnel and to provide some discretionary income.

We will ensure that personnel‘s wages and benefits composition are detailed clearly and regularly in writing for them for each pay period. We shall also ensure that wages and benefits are rendered in full compliance with all applicable laws and that remuneration is rendered either in cash or check form, in a manner convenient to workers.

Anti-Slavery and Human Trafficking Policy Statement   

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers, including children. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.  

We have a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.  

This policy applies to all employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the Policy 

Our directors have a responsibility for the prevention of modern slavery and for investigating allegations of modern slavery in the business or supply chains.  

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.   


The prevention, detection and reporting of modern slavery in any part of the company business or supply chains, is the responsibility of all those working for us.   We are to avoid any activity that might lead to a breach of this policy. 

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the company business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions with any of the company supply chains constitutes any of the various form of modern slavery, please raise it with you line manager. You can also contact the Government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery or file a report online.  

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of the company business or supply chains.  

Breach of Policy 

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.  

We may terminate commercial relationships with suppliers, contractors and any other business partners if they breach this policy and/or found to have been involved in modern slavery.