Anti Slavery & Human Rights Policy
]Introduction
The enactment of the Modern Slavery Act 2015 places obligations on The Company to ensure that it has policies and procedures in place to ensure modern slavery and human trafficking are not taking place anywhere within its own business, its supply chain, contractors and other business partners/stakeholders. We set ourselves the highest standards in relation to acting ethically, with integrity and transparency in our business dealings and expects the same impeccable standards from all of our stakeholders.
Overview
Modern slavery and human trafficking result in unacceptable abuses of the human rights of vulnerable people and can take various forms including forced or compulsory labour, servitude and slavery. Identifying potential victims of modern slavery can be difficult because it is insidious and takes many forms. There is a range of exploitation and a tipping point between where poor working conditions and lack of proper health and safety provisions, for example, become human trafficking, slavery or forced labour. Additionally, perpetrators may take extreme measures to hide that their practices are illegal. However, we recognise that we have a duty to have in place due diligence processes to ensure that workers are not being exploited and that all legal requirements of UK legislation relating to human rights, employment and health and safety, including free movement and communications, are adhered to.
We value our reputation for ethical behaviour and expect all of our employees to act in accordance with both the letter and spirit of the legislation. Breaches of this policy and procedure, or failure to report such breaches in a timely manner, may be deemed to be gross misconduct and lead to summary dismissal.
The purpose of this policy and procedure is to limit the business’s exposure to modern slavery and human trafficking by:
· Setting out a clear anti- modern slavery and human trafficking policy
· Communicate our zero tolerance to modern slavery and human trafficking to all stakeholders
· Training all employees and Board members so that they are able to recognise where modern slavery and human trafficking may be occurring
· Encouraging employees to be vigilant and provide appropriate reporting methods to ensure that sensitive information is used correctly
· Rigorously investigating allegations of modern slavery and human trafficking, assisting the police and other appropriate authorities in investigations and prosecutions
· Taking appropriate action against any individual(s) found to be involved in modern slavery and human trafficking
· Cease relationships with any stakeholder involved in modern slavery and human trafficking
This policy applies to Board members, employees, third party contractors who undertake work for the organisation.
It is the responsibility of every employee, Board member, employee and persons acting on behalf of the business, to ensure that modern slavery and human trafficking is an unacceptable practice and to ensure that they participate in the prevention, detection and reporting of any such actions. If you suspect or have evidence of modern slavery and/or human trafficking taking place within the organisation, or any of its stakeholders, it is your responsibility to report the matter, in confidence, to Helen Stead, Head of People & Culture by email at helen.stead@native-communities.com.
If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of our supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
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 or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our business or in any of our supply chains.