Anti-Slavery and Human Trafficking Policy

We Are Zacapa Ltd (“Zacapa”) is committed to the highest ethical standards in ensuring that our business practices combat slavery and human trafficking. This policy outlines our commitment to preventing modern slavery and human trafficking in our business operations and supply chains.

Our Commitment

Zacapa has a zero-tolerance approach to slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our own business or in any of our supply chains.

Policy Scope

This policy applies to all persons working for Zacapa or on our behalf in any capacity, including employees, directors, officers, agency workers, agents, contractors, consultants, third-party representatives, and business partners.

Our Practices

  1. Risk Assessment and Due Diligence:
    • Conduct risk assessments to identify areas of potential risk in our supply chains.
    • Perform due diligence on suppliers to ensure they comply with legal and ethical standards.
  2. Supplier Code of Conduct:
    • Communicate our zero-tolerance approach to modern slavery to all suppliers, contractors, and business partners.
    • Require all suppliers to adhere to our Supplier Code of Conduct, which includes provisions related to anti-slavery and human trafficking.
  3. Training and Awareness:
    • Provide training to our employees to ensure they understand the risks of modern slavery and human trafficking in our operations and supply chains.
    • Encourage employees to report any concerns related to slavery and human trafficking.
  4. Reporting and Compliance:
    • Implement a whistleblowing policy to allow employees and other stakeholders to report any concerns related to slavery and human trafficking.
    • Investigate any reported concerns promptly and take appropriate action.
  5. Continuous Improvement:
    • Regularly review and update our policies and procedures to ensure they remain effective in preventing modern slavery and human trafficking.
    • Engage with stakeholders, including suppliers and business partners, to promote best practices and continuous improvement.

Our Supply Chains

Zacapa is committed to working with suppliers who share our values and commitment to preventing modern slavery and human trafficking. We expect our suppliers to operate in accordance with the principles set out in this policy and to take reasonable steps to ensure that their supply chains are free from slavery and human trafficking.


The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

Monitoring and Review

Zacapa will review the effectiveness of this policy regularly and update it as necessary. We will monitor our supply chains to ensure compliance with this policy and take corrective action where necessary.

Contact Us

If you have any questions or concerns about this policy or our practices, please contact us at:

We Are Zacapa Ltd