Modern Slavery Statement
Modern Slavery Statement for financial year 2019/20
Our high risk areas
We have a governance structure that review and manages the key risks to our business. With regard to Modern Slavery, our key risks areas are identified as :
Recruitment. This risk is mitigated by:
- Safe recruitment standards consistent with sector
- Criminal Record Checks
- Identify Checks
- Right to Work Checks
- Supporting policies, procedures and training
Suppliers: This is mitigated by:
- Approved provider process
- Contractual terms
- Trusted suppliers
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistle-blowing policy. We operate a whistle-blowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
We operate a supplier policy and maintain a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business
- They hold their own suppliers to account over modern slavery
- They pay their employees at least the national minimum wage / national living wage (as appropriate)
- We may terminate the contract at any time should any instances of modern slavery come to light
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.