Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Scope of the Modern Slavery Act 2015

The Act defines modern slavery as “slavery, servitude and forced or compulsory labour” and “human trafficking” (Modern Slavery). The Act requires commercial organisations operating in the UK (i.e. that supply goods or services from or to the UK) and have a global turnover above £36 million, to publish a statement each financial year, which sets out the steps they have taken to ensure there is no Modern Slavery in their business or supply chains. Our combined turnover is below this limit, but we nevertheless published this Modern Slavery Policy and commit to review it annually.

We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Our Due Diligence Processes

Because of the nature of the employment positions we offer, we consider the risk of Modern Slavery existing within our business to be low. Our focus is therefore on ensuring that people we recruit to our organisation have a right to work here and are doing so of their own volition. We operate a right to work check system, as detailed below:

Right to Work Check

Any person who applies for employment with us is subject to a right to work check before a job offer is made to that person.
This check ensures that we are compliant with the Immigration Act 2016, but also reduces the risk of employing a person who is the victim of forced or compulsory labour.
We will verify the identity of job applicants and existing employees by checking the authenticity of the official documents the applicant provides as proof of identity, and we will check that:

• Documents presented are genuine, and
• That they relate to the person presenting as a proof of identity

By checking the above, we can establish a ‘right to work’ in the UK for anyone identified as an EU citizen, and to check the authenticity of any work permit provided by an applicant from a non-EU country that gives them a right to reside and work in the UK. This reduces the risk of employing a person who has been trafficked or is working under duress.

Our Supply Chain

To deliver our services, we work with a small range of suppliers, all of whom are based in a low-risk jurisdiction, i.e., the United Kingdom.

The contractual terms and conditions that we put in place with our suppliers are being updated to include clauses that forbid the use of slavery and human trafficking.

Training

We will inform and highlight the steps that our team members can take if they are concerned about any such type of behaviour, and we will also take steps to ensure that our suppliers are aware of our policy. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Whistleblowing

We operate a Whistleblowing Policy and all team members are informed of their responsibility to voice any concerns to management or our HR department, which will deal with these concerns in the strictest confidentiality. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.