Modern slavery and human trafficking policy

1. Introduction

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 which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking.

2. Legislation

We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. As we grow, we will ensure we apply good practice so when required to report, we will have been applying the practices for several years.

Considering the obligation to report on measures to ensure all parts of our business and supply chain are slavery free, we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our supply chain is quite extensive in the delivery of energy efficiency measures to domestic properties across Great Britain. We will support our direct partners to work towards making their own statements where they are missing, and work with other larger businesses to learn lessons and support our governance.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

3. Mitigation

As part of our initiative to identify and mitigate risk we have put in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

4. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business we intend to provide training to our staff. We will also require our supply chain partners to provide training to their staff and suppliers and providers.

5. Further steps

Following a review of the effectiveness of the steps we took 2018 to ensure there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

• Conduct a review to bring insights on ways to we can tackle slavery and human trafficking.
• We will use appropriate KPIs to assess how effective we have been in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains.
• Expand our knowledge through relevant events, learning and engaging with others.
  
  

6. Warning signs

When engaging suppliers, be vigilant for the signs of modern slavery and human trafficking. If you have concerns immediately raise them with your line manager, take photographs and record details and appropriate. Potential signs:

• Unusual travel or working times.
• Restricted freedom of movement.
• Living conditions – at the place of work.
• Clothing – limited changes of clothing or limited personal possessions.
• Inappropriate work clothing – poor quality PPE.
• Physical appearance.
• Always accompanied.
• Rarely interact and seem anxious.

7. If you suspect something is wrong

Record information and evidence.

Call 0800 0121 700 (www.modernslaveryhelpline.org) and discuss what we have seen and ask for advice on how to approach the situation.

Immediately raise the concerns with the supplier contact, providing the information and asking for an immediate verbal response and a written response in five working days.

Review the immediate and written response against our experience and understanding of the situation. Where there is inconsistency, seek further clarification, and if this is not forthcoming escalate to the authorities.

8. Response and remediation framework

As every situation is different and we do not expect to come across many, we utilise “Modern slavery response and remedy framework.” By Walk Free. This document provides a workable framework to follow, outlining actions to be taken to facilitate remedy in situations where a company is involved in exploitative labour practices or modern slavery.

Step One: Investigate and verify

Step Two: Remediate harm to workers

Step Three: Mitigate and prevent future harm

Step Four: Escalation

Step Five: Incident reporting and tracking

Step Six: Review

9. Related documents

01.01 - YES values and code of conduct

04.01 - Professional conduct policy

13.01 - Corporate and social responsibility statement

04.02 - Safeguarding policy

Walk Free Modern slavery response and remedy framework

Thank you for reading this policy.