Modern Slavery Statement

Modern Slavery is a crime that results in an abhorrent abuse of human rights. The Modern Slavery Act 2015, referred to as the Act, created offences of slavery, servitude and financial or compulsory labour.

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Slavery, following the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ownership of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he or she did own the person, which deprives the victim of their freedom.

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Servitude is the obligation to provide services that are imposed by the use of coercion and includes the obligation of a serf to live on another person’s property and the impossibility of changing his or her condition.

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Forced or Compulsory Labour is defined in international labour law by the International Labour Organisations (ILO) Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that, work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/herself voluntarily.

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Human Trafficking is an offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to travel. This reflects the fact that a victim may be deceived by the promise of a better life or job, or maybe a child who is influenced to travel by an adult. In addition, the exploitation of a potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view of exploiting them for sexual exploitation or non-sexual exploitation.

Child Labour is defined by the ILO as children under 12 years working in any economic activity, those aged 12-14 engaged in more than light work, and all children engaged in the worst forms of child labour.

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The transparency in supply chains provision within the Act seeks to address the role of businesses, across all sectors preventing modern slavery in their supply chains and organisations. The following guidance sets out how businesses can meet these requirements, as set out in the Act.

There is a requirement that any commercial organisation, in any sector, which supplies goods and services, and carries on a business, or part of a business, in the UK and is above a specified total turnover, must produce a slavery and human trafficking statement for each financial year of the organisation.

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Regulations have set the total turnover threshold at £36 million, The statement must set out what steps they have taken during the financial year to ensure modern slavery is not occurring in their supply chains and their organisations. The Act requires businesses to be transparent about what is happening within their business, therefore if the business has taken no steps to ensure slavery and human trafficking is not taking place, they must still publish a statement stating this to be the case.

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Failure to comply with the production of a modern slavery statement for a particular financial year could mean an injunction through the High Court (or In Scotland, the Court Proceedings for Specific Performance of a Statutory Duty under Section 45 of the Court of Sessions Act 1998) requiring the organisation to comply. Failure to comply with the injunction is a contempt of a court order which is punishable by an unlimited fine. In practice, failure to comply with the provision will mean the organisation has not produced a statement or published it on their website in the relevant financial year.

Reporting

When staff believe there is a possibility of a modern slavery situation, they must in the first instance report it to their manager who will then take it forward by reporting it to the Modern Slavery Helpline via telephone, 08000 121 700, or online, https://www.modernslaveryhelpline.org/report.

Responsibility for the policy

The board of directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Due Diligence

Our suppliers are required to confirm compliance with relevant legislation including the Modern Slavery Act.

Training Statement

All staff, during induction, are made aware of the organisation’s policies and procedures, all of which are used for training updates. All policies and procedures are reviewed and amended where necessary, and staff are made aware of any changes. Observations are undertaken to check skills and competencies. Various methods of training are used, including one to one, online, workbook, group meetings, and individual supervisions. External courses are sourced as required.

As part of our Induction process staff are aware of the Modern Slavery Act and how to report any concerns. We also train our managers to ensure they understand their responsibilities and are carrying them out. Information and help can be accessed on the phone number and website above.

Breach of the policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and / or are found to have been involved in modern slavery.

Supporting Policies and Procedures

We operate a number of internal policies and procedures that ensure we are conducting our business in an ethical, fair and transparent manner. These include:

• Adult Safeguarding

• Confidentiality

• Data Protection Legislative Framework (GDPR)

• Good Governance

• Recruitment and Selection

• Safeguarding Children in an Adult Setting

• Whistleblowing

• Young People and Employment