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What Is Slavery?
The Modern Slavery Act 2015 covers four activities:
Slavery | Exercising powers of ownership and total empowerment over |
Servitude | The obligation to provide services which have been imposed by the use of coercion. |
Forced or compulsory labour | Work or services exacted from a person under the menace of penalty and for which the person has not offered voluntarily, |
Human trafficking | Arranging or facilitating the travel and/or movement of another person with a view to their exploitation. |
The Modern Slavery Act 2015 covers four activities, listed in the table above. This policy covers all four activities.
How Is It relevant to us?
Responsibilities
The Company
We will:
Managers
Managers will:
Colleagues
We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
The Risks
The principal areas of risk we face, related to slavery and human trafficking, include:
Our Procedures Anti-Slavery Statement
We make a clear statement that we take our responsibilities to our employees, people working within our supply chain and our clients seriously, and this is updated once a year.
Supply Chains
We tell the companies we do business with, that we are not prepared to accept any form of exploitation.
From the date of this policy, all relevant supplier contracts will contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.
We apply reasonable due diligence to risk assessing our supply chain and use the following mechanisms to do this:
Recruitment
The Company follows firm policy and only uses agreed specified reputable recruitment agencies where necessary.
We expect all recruitment agencies with whom we engage:
If the Company has reason to believe that any recruitment agency has failed to meet these standards, HR should be informed and any contracts with them would be terminated.
We keep agents on the list under regular reviews.
General Recruitment
(a) We always ensure all staff have a written contract of employment.
(b) We always ensure staff are legally able to work in the UK.
(c) We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
If, through our recruitment process, we suspect someone is being exploited, the HR will be informed and the HR department will follow our reporting procedures (See Reporting Slavery).
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 or trafficking victim:
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 to the HR Department who will follow our reporting procedures.
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 the Human Resources Manager who will decide a course of action which may include contacting the police.
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 the HR Department before taking any further action.
Training
We ensure that all employees are made aware of this policy, and their obligation to comply with this policy.
Monitoring Our Procedures
We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.
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