The Modern Slavery Act 2015 (MSA 2015) focuses specifically on the issue of modern slavery to ensure offenders are suitably reprimanded with severe sentences. Modern slavery encompasses the offences of: ‘slavery’ where ownership is exercised over a person; ‘servitude’ which involves the obligation to provide service imposed by coercion; ‘forced or compulsory labour’ involves work or service exacted from any person under menace of a penalty and for which the person has not offered themselves voluntarily; and ‘human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them.
The MSA 2015 requires large businesses, with sales of over 36 million, to be transparent about their efforts to eradicate Slavery and Human Trafficking. This statement therefore explains the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business.
We have policies in place internally, which are available to all staff and these can be accessed by third parties on request, simply contact our HR Advisor for a copy. Our policies are reviewed annually by the organisation’s Human Resources department and legal advisors to ensure we remain compliant.
As part of the organisation’s induction process and throughout workers’ employment with us, we train all staff to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We offer training and development program for all staff from the ground floor through to management. We focus on ensuring all management team is not only aware of the requirements to be alert to modern slavery but also can address concerns raised by their team or any suppliers. If any worker is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination.
In relation to our supply chains, we use our reasonable endeavours to conduct risk assessments of the third parties we work with and investigate, where feasible, the working conditions of their workers.
As part of our risk assessments, we have procedures in place to identify whether there is a possible risk of slavery and human trafficking either in the business or our supply chain. As a result, we have taken the following steps to assess and manage the risk which includes conducting regular audits or our supply chains which fall in countries where protection against breaches of human rights are limited. We aim to work with our colleagues and suppliers to ensure collaboration to remedy or mitigate such risks.
We allow all individuals who work or provide services to us right to freely choose employment and, the right to associate freely with other individuals. Workers are free to choose whether to join a trade union or not and as a result of our training, we offer an environment which is free from harassment and unlawful discrimination. We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero-tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such involuntary labour with their workers, subcontractors, agents or associates.
We aim to ensure that our performance indicators do not put pressure on or influence any modern slavery risk.
As a result of a risk assessments, we have introduced additional performance indicators, such as training about modern slavery issues, measure awareness of risk; improve grievance and whistleblowing procedures which we have introduced to measure the performance of anti-slavery actions and the progress against reducing such risk.