Modern Slavery and Child Labour Remediation Policy

Policy statement

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. 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.

About this policy

2.1

The purpose of this policy is to:

2.1.1

set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and

2.1.2

provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

2.2

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.

2.3

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Definitions

Wording
Child Labour:	Work that harms, abuses and exploits a child or deprives a child of an education. It refers to working children below the age of completing compulsory education in the country of manufacture.
Ethical Trading Initiative (ETI) Base Code	The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.
Modern slavery	A broad term used to encompass offences that involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.
Forced labour	All work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
Human trafficking	The recruitment and transportation of persons by threat, force, coercion or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.
Hidden labour exploitation	The action up to and including modern slavery which involves the exploitation of workers and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or labour provider.

Responsibility for the policy

4.1

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2

The Site HR team has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

4.3

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4.4

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the HR team.

Your responsibilities and how to raise a concern

5.1

You must ensure that you read, understand and comply with this policy.

5.2

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.

5.3

You must notify your manager or our confidential helpline as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

5.4

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.

5.5

If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify your manager, or HR team or report it in accordance with our Whistleblowing Policy as soon as possible.

5.6

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or HR team or through the confidential helpline:

5.7

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 of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your HR team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

Training and Communication

6.1

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

6.2

Our commitment to addressing the issue of]modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.

Breaches of this policy

7.1

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

7.2

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

SEDEX

8.1

We are supplier members (AB) of SEDEX (Supplier Ethical Data Exchange) a not for profit membership organisation dedicated to driving improvements in responsible and ethical business practices in global supply chains and as such comply with the ETI base code. SMETA audits and corrective actions are uploaded to the Sedex platform, which allows us to undertake supplier risk assessments and decide on any actions we and the supplier need to take. As a condition of trade, all our suppliers must be registered with SEDEX and give us visibility of their ethical data. We will continue to improve communication on this topic with our supply chain and welcome opportunities to collaborate to identify risks or solve problems that we cannot tackle alone. We will face common issues and by working together, not only with suppliers but also with other UK companies, we will be far more effective in meeting our common goal of eradicating Modern Slavery.

Remediation Procedures

9.1

When Modern Slavery issues are identified in our business, we will act immediately and focus on the protection of the victims. We are committed to supporting our colleagues to deliver effective action which addresses root cause and provides meaningful improvement.

9.2

Where a case of child labour is identified or suspected, the victim will be taken to a place of safety while the local authority children’s social care team or the police are informed. The victim will remain supervised in a safe location until placed into the care of the police or local authority.

9.3

We operate an externally provided whistleblowing hotline which is available to all colleagues, enabling them to raise concerns directly and anonymously to our central HR team. All concerns raised are thoroughly investigated immaterial of the nature of the case. See Section 10.

9.4

In cases of modern slavery, including forced labour, trafficking or hidden third party exploitation of workers, occurring in either one of our own sites or in our supply chain and having a direct adverse human rights impact, the complainant should be able to produce sufficient information to demonstrate the relevance and seriousness of the complaint.

9.5

Protecting the victim of slavery must be the first priority of the remediation programme.

9.6

Once an allegation of modern slavery is made, victims should be:

–

Taken to a place of safety, out of view

–

Supported by a colleague or trade union representative if possible

–

Provided with reassurance and welfare (food, drink, medical assistance)

–

Given access to relevant government or third-party remediation services.

9.7

At all stages, we will take steps to protect confidentiality and collect evidence including:

–

Ensuring that suitable managers are responsible for running the investigation without links to the allegations

–

Recording what the victim says and making full notes of all the circumstances

–

Keeping multiple victims separate, speaking to them individually and noting signs of suspects trying to make contact

–

Having an independent/telephone interpreting service ready to use.

Our process for responding to violations will be to:

–

Conduct an initial assessment of the allegations to ensure that there is sufficient information to understand the exploitation discovered and remedy it

–

Ascertain if a supplier or labour provider is implicated

–

Report the allegations to relevant authorities

–

Capture evidence about the violations, using an independent third party if necessary

–

Gather information from those affected

–

Take steps to correct the situation for the worker

–

Contribute to programmes and projects to assist the victims of slavery

–

Work with local authorities and competent local organisations to provide assistance

–

Review progress over a suitable time period and verify that progress with local authorities and local organisations

–

Document remedial steps taken (see Remediation Reporting Tool in Appendix 2)

–

Build learnings into remediation procedures and operational procedures to prevent re-occurrence.

9.8

It is important that we monitor the progress of the remediation programme and provide ongoing support for victims of slavery. Monitoring will include the following steps:

–

Monitoring the victim’s progress if the victim has been referred to a government or civil society-managed referral mechanism or similar

–

Evaluating how effective the remediation procedure was and amending it accordingly

–

Reviewing internal policies and procedures to determine what needs to change to prevent slavery from re-occurring.

9.9

Ongoing support required should be determined with the victim. It may take the form of a financial support whilst the victim is not working.

10.

Navex EthicsPoint Confidential Helpline and Website

Telephone:0800 069 8730

Online: http://www.boparan.ethicspoint.com/

11.

Training and Communication

11.1

11.2

12.

Breaches of this policy

12.1

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

12.2

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

13.

The Policy and Remediation in Practice

We recognise that it is important to clearly set out how we manage and manage and monitor the business’s remediation procedure.

In designing this we have taken input from stakeholders including workforce representatives, local non-government organisations and organisations providing remedy for victims of modern slavery.

The following steps are incorporated into our Remediation Reporting Tool, section 14 of this policy:

–

Identify what constitutes a grievance (relating to Modern Slavery and Child Labour) and what information the complainant should be able to provide to demonstrate the relevance and seriousness of the complaint

–

Identify what channels are available to workers and relevant third parties for raising grievances – NAVEX or local HR Teams

–

Communicate to ensure that workers and relevant third parties are aware of all of these channels, including Labour agencies and suppliers of materials, goods and services

–

Document the investigation process and should a potential incident of modern slavery be identified using the Remediation Reporting Tool.

–

Identify and document what remedy the business will offer to victims of modern slavery, including restitution (restoring victim to original situation before abuses occurred), compensation (financial or otherwise), rehabilitation (medical, physiological or psychological care) and satisfaction and guarantee of non-repetition

–

Identify and document relevant government and/or civil society-backed support mechanisms that victims of slavery can access such as Modern Slavery Helpline, Stronger Together and/or Unseen UK

–

Ensure that that victims have the right to pursue other forms of remedial action at any stage beyond internal remedy mechanisms

–

Document how the business will contribute to programmes to assist victims of modern slavery, e.g. through vocational training or other appropriate measures

–

Document how the outcomes of any investigation will be communicated, bearing in mind the need to protect victims

–

Establish a review procedure to ensure that the remediation policy is effective and to review the root causes of any incidents of modern slavery – annual review of the policy and procedure

–

Share the remediation procedure with all workers on site – Employee App (Book of Everything) and notice boards.

14.

Remediation Reporting Tool

This is an illustration of the tool used for managing and documenting actions when cases of forced labour are found.

We will take the following steps once a case of forced labour has been identified:

Investigate the violations effectively, promptly, thoroughly and impartially and, where appropriate, we will take action against those allegedly responsible in accordance with domestic and international law.

Provide the victims of the human rights abuse with access to justice, irrespective of who may be responsible for the violation.

Provide effective remedy to the victims, including reparation.

Consider what needs to change to ensure that the abuses do not reoccur.

The information will be completed by the individual/s in the business who are responsible for implementing the Company’s policy for remedy of human rights abuses, usually the local HR team:

Required Information	Case-specific response
Location of abuse
Date/s of abuse
Nature of human rights abuse
Individuals or organisations responsible for human rights abuses
Investigation undertaken into the violations
Date/s of investigation
Findings of investigation
Access to justice offered to victim of abuse
Remedy requested by victim of abuse
Proposed remedy offered to victim of abuse
Actual remedial steps implemented
Steps taken to restore the victim to their original situation before the abuses took place. e.g. restoration of employment, return of property, payment of due wages
Steps taken to compensate the victim for the abuses that took place. This compensation may be financial or otherwise.
Steps taken to rehabilitate the victim. This may include medical and psychological care as well as legal and social services.
Steps taken to satisfy the victim that the abuses will not reoccur. This may include changes to business processes or the engagement of government.
Timeframe for remedy
Involvement of suppliers in remedy
Involvement of local groups/NGOs/charities in remedy
Involvement of victim’s family in remedy
Involvement of local or national government in remedy
Other comments

Modern Slavery and Child Labour Remediation Policy

June 2023