This Modern Slavery and Human Trafficking Statement sets down our commitment to working towards preventing slavery and human trafficking in our business activities, and the steps we have put in place and continue to develop, with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them. As part of the supply chain, we undertake due diligence to ensure we are not entering into a contract or services that could be misconstrued and demand of our suppliers the highest credentials. This also includes any agencies that supply our companies with temporary labour. We undertake company checks and satisfy ourselves of the viability of the company we do business with. We would also take account of any Foreign Office advice relating to countries we provide services to. The following activities are considered to be at high risk of modern slavery or human trafficking: Employment of foreign nationals who are not permitted to work in the UK and vehicles or those of our suppliers crossing UK borders. Responsibility for our anti-slavery initiatives are as follows:
Human Resources in each business unit are responsible for creating and reviewing policies. The process by which policies are developed is to review best practice and legislation and adapt policy to the needs of the organisation.
The Compliance Manager and Health & Safety and Process Manager is responsible for risk assessments in respect of human rights and modern slavery by a process of planned review, audit and control activities.
Human Resources and Finance departments, along with the Compliance Manager and Health & Safety and Process Manager are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the organisation requires all relevant staff to undertake online awareness training in Modern Slavery and Human Trafficking. The organisation operates the following policies that describes its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy – The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form
- Employee code of conduct – The organisation’s code contained in employee handbooks makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain
- Supplier/Procurement code of conduct – The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship
- Recruitment policy – The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. We regularly audit employment agencies we use to ensure that all right to work and identity checks are being carried out
- Corporate Social Responsibility (CSR) Policy – The organisation’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities
Performance indicators The Group uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains: The use of labour monitoring and payroll systems; Outcomes of employment agency auditing process; Annual risk assessment data; Number of complaints raised.