1.1 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. Our organisation has 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.
1.2 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.
1.3 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.
2. Responsibility for the policy
2.1 The Chairman and Trustees have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Coordinator has primary day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal systems and procedures to ensure they are effective in countering modern slavery.
2.3 Staff and volunteers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are aware of the issue of modern slavery in supply chains.
3. Compliance with the policy
3.1 All staff and volunteers must read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 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.
3.4 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery may be taking place in any part of our organisation or in any of our supply chains. Detrimental treatment includes disciplinary action or other unfavourable treatment connected with raising a concern.immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
4. Communication and awareness of this policy
4.1 Training on this policy forms part of the induction process for all individuals who work for us.
4.2 Our zero-tolerance approach to modern slavery must be communicated to suppliers, contractors and business partners at the outset of our business relationship with them.
Appendix 1: Guidance on how to spot the signs of modern slavery
Below is a list of some of the more common signs of modern slavery:
Physical and psychological abuse: Many victims will look malnourished and may appear withdrawn when you try to communicate with them. Signs of physical abuse could be apparent, such as bruising and other injuries.
Restricted movement: Victims may not be allowed to travel alone and will not be in possession of their passport. They may seem under the influence of others, have little interaction, and be unfamiliar with the surroundings in which they are working.
Poor accommodation: A victim of modern slavery will likely have an extremely poor standard of living, often staying on site in cramped and dirty conditions with other workers. It is also quite possible that they would not know their home or work address.
Lack of personal belongings: As well as having no form of identification, such as a passport, a victim of modern slavery will likely have very few personal possessions and wear the same clothes every day. These clothes could appear unsuitable for their working conditions.
Unusual behaviour: It is quite common for victims of modern slavery to avoid eye contact, continually appear frightened, and allow others to speak for them when addressed directly. They will be very reluctant to ask for help, quite possibly due to fear of further abuse or fear of deportation.