MODERN SLAVERY statement
Policy Statement
definition
The Company believes that modern slavery includes the following aspects:
- Human trafficking
- Forced labour – involving mental or physical force
- Being subjected to ownership or control by an employer through mental or physical abuse or the threat of abuse
- Dehumanization, treating individuals as commodities, or their sale as property
- Physical confinement or limitations on freedom of movement
Commitment
The Company recognizes its obligations in addressing modern slavery and is dedicated to sticking to the stipulations outlined in the Modern Slavery Act 2015 (The United Kingdom). The Company acknowledges that this entails continuous assessments of its internal procedures concerning its workforce and its supply chains.
The Company is committed to avoiding any business associations with other companies, whether in the United Kingdom or overseas, that are known to support or engage in slavery, servitude, or forced or compulsory labor.
The Company ensures that all labour provided to support its services is acquired without the use of slavery or human trafficking. The Company not only complies with the minimum standards stipulated by applicable employment legislation in the UK but often surpasses these minimum requirements when it comes to its employees.
Supply chains
The Company is dedicated to guaranteeing that its supply chains are free of slavery. The principal supply chains for the Company encompass various areas, such as offices, consultants, agency workers, recruitment agencies, security personnel (including CCTV operations), delivery services, and professional services. The Company acknowledges that its primary suppliers are intermediary traders, which implies that it maintain additional contractual connections with lower-tier suppliers.
To ensure that our supply chains remain free from slavery, we have put in place the following measures:
- Our standard contracts include an anti-slavery clause, obligating our suppliers to comply with the Modern Slavery Act and related legislation.
- Contracts incorporate a clause allowing us to audit suppliers annually to assess their compliance with the Act.
- We employ best practices when engaging with suppliers.
- We exclusively work with reputable agencies that have established contracts for each appointment when hiring staff.
- All staff recruited through agencies must provide right-to-work documents as part of our pre-employment checks.
- We adhere to regulations concerning agency staff reaching 12 weeks of engagement.
- Every new and existing supplier is requested to furnish their Modern Slavery Policy or Statement as proof of compliance with the Modern Slavery Act. Failure to provide such proof will raise concerns, and we will seek alternative suppliers or contractors.
- Before procurement, all personnel responsible for specific aspects of purchasing are well-versed in the Modern Slavery Act and request evidence from new suppliers.
- Everyone involved is trained and knowledgeable about the Act and adheres to the aforementioned guidelines.
- We are committed to keeping our policies and procedures up to date, ensuring compliance with legislative changes, including the Modern Slavery Act.
- As a condition of procurement and contracting, suppliers and contractors must demonstrate adherence to employment legislation and, if applicable, compliance with the annual reporting requirements outlined in section 54 of the Modern Slavery Act.
Potential exposure
The Company identifies the primary risk of slavery and human trafficking to be associated with the procurement of goods produced overseas, particularly in regions where safeguards against human rights violations may be insufficient. Overall, the Company believes that its risk of encountering slavery and human trafficking is relatively low. Nevertheless, it has implemented measures to prevent these practices from occurring within its operations and those of its suppliers of goods and services.
In case of ANy pandemic(s)
In the event of a pandemic, the company will adhere to government guidelines and implement necessary restrictions on its operations, including those involving its employees, suppliers and others as dictated by the prevailing circumstances and recommendations.
Even in the midst of a pandemic, the Company’s employees retained access to the grievance procedure to voice any concerns they might have had. In compliance with emergency legislation enacted by the Government, employees were provided with Statutory Sick Pay or company sickness payments when required to self-isolate, especially in cases where temporary remote work arrangements could not be agreed upon. The Company continued to monitor and address modern slavery risks during the pandemic using the same procedures as in regular times.
steps
The Company conducts due diligence procedures to ensure that slavery and human trafficking do not occur within its own operations or supply chains. This includes reviewing and assessing the controls and practices of its suppliers to prevent and address any potential risks associated with modern slavery.
To the best of its knowledge, the Company has not engaged in any business dealings with other companies that have been identified as being involved in modern slavery practices.
In compliance with section 54(4) of the Modern Slavery Act 2015, the Company has implemented the following measures to prevent modern slavery:
- Examining the Company’s supplier agreements to incorporate provisions that grant termination authority in cases where the supplier is, or is reasonably suspected of being, engaged in modern slavery practices.
Conducting annual supplier audits to assess and ensure compliance with the Act. Adhering to best practices when engaging with suppliers to minimize the risk of modern slavery in the supply chain.
- Work on strategies and plans to mitigate the risks associated with modern slavery. Measures in place to firmly establish and uphold a policy of ‘zero tolerance’ toward modern slavery.
- Ensuring that all personnel engaged in procurement activities have completed the appropriate internal training.
Key performance indicators
The Company has established the following key performance indicators (KPIs) to assess how effectively it is preventing modern slavery within the Company and its supply chains. Documentation confirming compliance with the Act will be requested from both current and prospective suppliers and contractors, and records of online training completion will be maintained for all staff.
Policies in place
The Company has implemented the following policies to provide a more detailed framework outlining its position on modern slavery:
- Recruitment & Selection Policy
- Anti-Corruption and Bribery Policy
- Anti-Harassment and Bullying Policy
- Whistleblowing Policy
- Disciplinary and Grievance Policies
- Salaries and Payments Policy
- Modern Slavery Training Policy
Slavery Compliance Officer
The Company has designated a Slavery Compliance Officer responsible for addressing all concerns related to modern slavery. This officer will take appropriate action following the Company’s obligations.
This statement is issued in accordance with Section 54(1) of the Modern Slavery Act 2015 and will undergo a review at the end of each financial year.