Modern Slavery Statement
We are committed to ensuring there is no modern slavery or human trafficking in any part of our business, or in our supply chain. We are committed to acting ethically and with integrity in all our business relationships and taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any sort of a business relationship with our Company.
All employees are checked for their eligibility to work in the UK by our HR department who perform the required right to work checks of all employees.
Modern slavery can take various forms, such as, servitude, forced or compulsory labour and human trafficking. Modern Slavery is a global issue and the Company has put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains.
The Company has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chains, consistent with our obligations under the Modern Slavery Act 2015.
Policies and Control
The Company expects the same high standards from all its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.
The Company’s policies that demonstrate commitment to its zero-tolerance approach to Modern Slavery are:
- Anti-slavery and Human Trafficking Policy
- Equal Opportunities Policy
- Anti-bribery and Corruption Policy
- Grievance Policy and Procedure
- Whistleblowing Policy
Due Diligence Process
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour.
However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
We will not support or deal with any business knowingly involved in slavery or human trafficking. We work with reputable recruitment companies and expect them to implement effective anti-slavery policies.
The Company implements the following:
- Compliant Right to Work and Identity checks
- Ensuring compliance with National Minimum Wage or National Living Wage legislation
- Compliance with statutory payments for holiday pay, sickness, maternity and other benefits
The Company follows a client/new business onboarding process that includes the following:
- Check of website domain
- Credit checks
- Company and VAT number checks
- Ensuring that the Company accounts have been filed
- Anti-money laundering checks
Line managers are responsible for ensuring that those reporting to them understand and comply with this Statement.
This Statement applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
The Board of Directors has overall responsibility for ensuring that this Statement complies with the Company’s legal and ethical obligations.
The Managing Director has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery.
They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.