Modern Slavery Policy
Modern Slavery Act 2015
Group Statement - Policy & Procedures
The company is committed to and meets the objectives of the Modern Slavery Act 2015.
The UK Government introduced the Act during 2015, the act requires any group or company with an annual turnover in excess of £36 million to publish their statement which sets out the steps that the group have and will continue to take during each financial year, to ensure that slavery and human trafficking are not taking place.
The group, supported by the board of directors actively ensure that any associate business also conforms to the Act.
The Act Definition
The Modern Slavery Act, the first of its kind in Europe, received Royal Assent on 26 March 2015.
The act consolidates slavery and trafficking offenses and introduces tougher penalties and sentencing rules.
It ensures that the main offences are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002, introduces bespoke slavery and trafficking compensation orders, and provides for the confiscation of vehicles, ships and aircraft used for the purposes of trafficking.
The changes will ensure that the National Crime Agency, the police and other law enforcement agencies have the powers they need to pursue, disrupt and bring to justice those engaged in human trafficking and slavery, servitude and forced or compulsory labour. It also introduces measures to enhance the protection of victims of slavery and trafficking.
A new Independent Anti-slavery Commissioner has been appointed whose role is to encourage good practice in the prevention, detection, investigation, and prosecution of slavery and human trafficking offences, as well as the identification of victims of those offences. This role is relevant to all current slavery and trafficking offences in England, Wales, Scotland and Northern Ireland.
The act includes provisions to: -
•Enable the Secretary of State to make regulations relating to the identification of and support for victims
•Make provision for independent child trafficking advocates
•Introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
•Close gaps in the law to enable law enforcement to stop boats where slaves are suspected of being held or trafficked
•Require businesses over a certain size and threshold to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chain.
Our Groups Requirement
An additional clause (clause 6) was added retrospectively to the act and requires organisations to report on the processes and due diligence taken to ensure that their supply chains are slavery free.
The transparency in Supply Chains clause came into force in Oct 2015 and requires organisations with a turnover of £36 million or more to produce and publish a slavery and human trafficking statement each financial year
The statement is a summary of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains.
A statement needs to be published regardless of whether any steps have been taken or not, as follows:
A slavery and human trafficking statement for a financial year is
a) a statement of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place — (i) in any of its supply chains, and (ii) in any part of its own business, or
(b) a statement that the organisation has taken no such steps.
The Report Must Contain
a)the organisation’s structure, its business and its supply chains.
b)its policies in relation to slavery and human trafficking;
c)its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
d)the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
e)its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate;
f)the training about slavery and human trafficking available to its staff.
Publishing Our Statement
The Act confirms that the group must publish annual report on the Groups website(s) and include a link on the websites home page to the report so that it can be easily seen and located.
The Procurement Cycle
To ensure that the group maintain their vigilance of the Act we have an agreed Procurement system in place.
When looking at new suppliers the Group or its representatives (including sub-contractors and commission based support) have an obligation to ensure that the supplier, sub-contractor or other parties fully comply with the Act, if they are over the threshold of £36 Million per financial year that they have published their statement in full compliance of the Act.
If they are below the threshold that they agree to and abide by our policies which will in all cases require a written statement to the Board of Directors annually to show their full compliance.
Our current suppliers who have a registered office within the United Kingdom or Europe must ensure that they produce and comply with the Act, it must be a condition of supply that they complete an annual statement each financial year and supply a copy of this statement to us within 42 days of their financial year end.
For suppliers who are based outside of the EEC or United Kingdom the onus falls on us to show that we have taken all reasonable steps to ensure that Act is followed and at no point in the supply chain has there been a breach in the Act.
Our Group Annual Statement
Will be completed at the financial year end and will be signed off by at least one director. This statement will be published on the Groups corporate website home page within 42 days of the end of the financial year.
This policy will be reviewed at the most annually, or sooner if required.