Modern Slavery Act (MSA) 2015 covers four activities:
Slavery
Exercising powers of ownership over a person.
Servitude
The obligation to provide services is imposed by the use of coercion.
Forced or Compulsory Labour
Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
Human Trafficking
Arranging or facilitating the travel of another person with a view to their exploitation.
This policy of the Employer covers all four activities.
The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
With this in mind, the Employer needs to pay particularly close attention to (where applicable):
the supply chain;
any outsourced activities, particularly to jurisdictions that may not have adequate safeguards;
external suppliers;
corporate hospitality.
responsibilities
The Employer as an organisation, in addition to individual managers and colleagues, have responsibilities to ensure fellow workers and third parties are safeguarded, and that they are treated fairly and with dignity.
Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.
The Employer
The Employer will:
maintain clear policies and procedures preventing exploitation and human trafficking, and protecting the workforce and the Employer’s reputation;
be clear about the recruitment policy in place (see ‘Recruitment’);
check supply chains (see ‘Supply Chains’);
lead by example by making appropriate checks on all workers, recruitment agencies, suppliers, etc. to ensure there is knowledge of who is working for the Employer;
ensure there is in place an open and transparent grievance process for all staff;
seek to raise awareness so that colleagues know what the Employer is doing to promote their welfare;
Managers
Managers will:
listen and be approachable to colleagues;
respond appropriately if they are told something that might indicate a colleague, or any other person, is in an exploitative situation;
remain alert to indicators of slavery (see ‘Identifying Slavery’);
raise the awareness of colleagues, by discussing issues and providing appropriate training, so that everyone can spot the signs of trafficking and exploitation and know what to do;
use their experience and professional judgement to gauge situations.
Colleagues
There is a collective responsibility under this policy. Whatever your role or level of seniority, you must:
maintain awareness – if you suspect someone (a colleague or someone in the Employer’s supply chain) is being controlled or forced by someone else to work or provide services, the Employer’s reporting procedure must be followed (see ‘Reporting Slavery’);
follow the Employer’s reporting procedure if a colleague tells you something you think might indicate they, or someone else, is being exploited or ill-treated;
tell the Employer if you think there is more that can be done to prevent exploitation from taking place.
the risks
The principal areas of risk the Employer faces, related to slavery and human trafficking, include:
supply chains;
recruitment through agencies;
general recruitment.
The Employer manages these risk areas through procedures set out in this policy and elsewhere.
the employer’s procedures
Supply Chains
The Employer thoroughly checks supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
The Employer tells the companies it does business with that the Employer is not prepared to accept any form of exploitation.
The Employer ensures it can account for each step of its supply processes, and knows who is providing goods and services to the Employer, and the Employer ensures that it has appropriate mechanisms in place to carry out checks where necessary.
Recruitment
Using Agencies
To ensure the potential for slavery and human trafficking is reduced as far as possible, the Employer thoroughly checks recruitment agencies before utilising their services and/or adding them to the list of approved agencies. This includes:
conducting background checks;
investigating their reputation;
ensuring the staff an agency provides have the appropriate paperwork (e.g. work visas);
ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying.
General Recruitment
The Employer always ensures all staff have a written contract of employment, and that they have not had to pay any direct or indirect fees to obtain work.
The Employer always ensures that staff are legally able to work in the UK.
The Employer checks the names and addresses of staff (a number of people listing the same address may indicate high shared occupancy, which is often a factor for those being exploited).
The Employer provides information to all new recruits on their statutory rights, including sick pay, holiday pay, and any other benefits they may be entitled to.
If, through the recruitment process, the Employer suspects someone is being exploited, the Employer’s reporting procedures will be followed (See ‘Reporting Slavery’).
identifying slavery
There is no typical victim, and some victims do not understand they have been exploited, and that they are entitled to help and support.
However, the following non-exhaustive list includes key signs that could indicate that someone may be a slavery or trafficking victim:
the person is not in possession of their own passport, identification, or travel documents;
the person is acting as though they are being instructed or coached by someone else;
they allow others to speak for them when spoken to directly;
they are dropped off and collected from work;
the person is withdrawn, or they appear frightened;
the person does not seem to be able to contact friends or family freely;
the person has limited social interaction or contact with people outside their immediate environment.
Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
If you have a suspicion, this should be reported in accordance with the Employer’s reporting procedures (see ‘Reporting Slavery’).
reporting slavery
Talking to someone about your concerns may stop someone else from being exploited or abused.
If you think that someone is in immediate danger, dial 999.
Otherwise, you should discuss your concerns with your Manager and/or the Director who will decide a course of action and provide any further advice.
Not all victims may want to be helped, and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with your Manager and/or the Director before taking any further action.
training
The Employer provides appropriate training to those staff members who are involved in managing recruitment and the Employer’s supply chains, and more general awareness training is provided to staff where it is deemed necessary.
The Employer will review this policy regularly, and will provide updates and information and/or training (where necessary) on any changes that are made.
