Anti-Slavery Policy
This policy applies to anyone working for our companies. This includes employees, workers, contractors, volunteers, interns and apprentices. The policy also relates to job applicants and is relevant to all stages of the employment relationship.
Introduction
Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. You may think this whole subject is irrelevant to us, but it is not. At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and
reputation makes good business sense.
The Modern Slavery Act 2015 covers four activities:
Slavery: Exercising powers of ownership over a person
Servitude: The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour: Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human Trafficking: Arranging or facilitating the travel of another person with a view to their exploitation
This policy covers all four activities.
The Modern Slavery Act 2015 recognises the important part organisations can and should play in tackling slavery. With this in mind, we need to pay particularly close attention to:
• our supply chain
• any outsourced activities, particularly to jurisdictions that may not have adequate
• safeguards.
Responsibilities
Our companies, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity. Everyone must observe this policy and be aware that turning a blind eye is unacceptable.
Our companies will:
a) Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
b) Be clear about our recruitment policy.
c) Check our supply chains.
d) Lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us.
e) Ensure we have in place an open and transparent grievance process for all employees.
f) Seek to raise awareness so that our colleagues know what we are doing to promote their welfare.
g) Make a clear statement that we take our responsibilities to our employees and our clients seriously.
Managers will:
a) Listen and be approachable to colleagues.
b) Respond appropriately if they are told something that might indicate a colleague is in an exploitative situation.
c) Remain alert to indicators of slavery.
d) Raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do.
e) Use their experience and professional judgement to gauge situations.
Colleagues will:
We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
a) Keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure.
b) Follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
c) Tell us if you think there is more we can do to prevent people from being exploited.
The Risks
The principal areas of risk we face, related to slavery and human trafficking, include:
• supply chains
• recruitment through agencies
• general recruitment.
We manage these risk areas through our procedures set out in this policy and elsewhere.
Anti-slavery Statement
We make a clear annual statement that we take our responsibilities to our employees, people working within our supply chain and our employees seriously, and we make this statement as part of our companies reporting.
Supply Chains
We will check supply chains to ensure the potential for slavery and human trafficking is significantly reduced. We tell the companies we do business with that we are not prepared to accept any form of exploitation.
All our standard supplier contracts will contain an anti-slavery clause. This clause prohibits suppliers and their employees from engaging in slavery or human trafficking.
Using Agencies
a) Our HR department and recruiting managers follow our companies policy and only use agreed specified reputable recruitment agencies.
b) To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
• Conducting background checks
• Investigating reputation
• Ensuring the staff it provides have the appropriate paperwork (e.g. work visas)
• Ensuring the agency provides assurances that the appropriate checks have been
made on the person they are supplying.
• We keep agents on the list under regular review, at least every 2 years.
General Recruitment
a) We always ensure all employees have a written contract of employment.
b) We always ensure employees are legally able to work in the UK.
c) We provide information to all new recruits on their statutory rights including sick.
If, through our recruitment process, we suspect someone is being exploited, the HR department or recruiting manager will follow our reporting procedures.
Identifying Slavery
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery of trafficking victim:
a) The person is not in possession of their own passport, identification or travel documents.
b) The person is acting as though they are being instructed or coached by someone else.
c) They allow others to speak for them when spoken to directly.
d) They are dropped off and collected from work.
e) The person is withdrawn, or they appear frightened.
f) The person does not seem to be able to contact friends or family freely.
g) The person has limited social interaction or contact with people outside their immediate environment.
This list is not exhaustive.
Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you
have a suspicion, report it.
Reporting Slavery
Talking to someone about your concerns may stop someone else from being exploited or abused. If you think that someone is in immediate danger, dial 999. Otherwise, you should discuss your concerns with HR or your line manager who will decide a course of action and
provide any further advice in accordance with the Safeguarding Policy.
Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with HR or Line Manager before taking any further action.
Monitoring our procedures
We will review our Anti-slavery Policy regularly, at least annually. We will provide information on any changes we make.
Our Anti-Slavery Statement
Our companies have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all of its business dealings and relationships. We implement and enforce effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015 (section 54).
Our principles
Our commitment to human rights, including our position on forced labour, involuntary labour, child labour, and human trafficking, is outlined in our Anti-Slavery Policy. Our principles related to human rights include:
a) We are committed to protecting and preserving the rights of our employees, those employed in our supply chain, and those affected by our operations.
b) We believe that all employment should be freely chosen and commit to refrain from any form of forced or involuntary labour.
c) We are opposed to the use of any form of child labour or practices that inhibit the development of children.
d) We maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
Our Policies Related to Slavery & Human Trafficking
Our Anti-Slavery Policy underpins all our companies activity. It applies to all employees of our companies.
Our human rights approach is aligned to the principles stated within our Anti-Slavery Policy. Our Global Human Rights policy sets out our commitment to respect the human rights of our employees, and those working on our behalf, through core labour standards. It sets out
practical guidance for the implementation of processes and due diligence against each of our principles.