Modern Slavery policy
|Approved||19 July 2023|
|Published||25 July 2023|
|Effective||19 July 2023|
This Policy sets out Longhurst Group’s intent to understand all potential risks of modern slavery to our business and to put in place steps to mitigate against the risk of slavery or human trafficking in our business and our supply chains.
The Policy identifies where risks may arise and sets out how we will manage them.
Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, servitude, compulsory labour and human trafficking for exploitation and can have a significant adverse impact on individuals, families and communities across the world.
This Policy ensures compliance with the Modern Slavery Act 2015 and Article 4 of the European Convention on Human Rights. It meets our ethical obligations and best practice as an employer, service provider and business partner.
- Longhurst Group will operate in an open and transparent way.
- We recognise the expectation that we will maintain high ethical standards and best practice.
- We recognise our responsibility to take a robust approach to slavery and human trafficking. We recognise our obligations to identify, target and prevent slavery and human trafficking and we understand that everyone has a role to play in this.
- We have a zero-tolerance approach to modern slavery across all areas of our organisation, as well as in our supply chains.
This Policy applies to all employees, including fixed term and temporary employees, volunteers, apprentices, agency, and reserve workers; contractors; external consultants; third party representatives; and business partners.
If customers raise concerns in respect of Modern Slavery regarding an employee of the Group, they should raise their concerns with either the Safeguarding Lead or Company Secretary.
The Policy does not form part of any employee’s contract of employment, and we may amend the Policy at any time.
As we operate solely within the UK we are at a low risk of exposure to slavery and human trafficking. A key area of risk however lies in our relationships with supply chains - suppliers, contractors and business partners.
Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
We will undertake appropriate due diligence when considering taking on new suppliers, contractors, and business partners, and regularly review our existing suppliers, contractors, and business partners.
A Supplier Code of Conduct has been implemented. This will require all suppliers, contractors and business partners to confirm in writing their compliance with the Modern Slavery Act 2015 and include relevant clauses in any contracts or agreements.
Serious breaches of our supplier code of conduct would result in the termination of the business relationship
Employees are required to avoid any activity that might lead to, or suggest, a breach of this Policy. Employees will be encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our organisation or supply chains at the earliest possible stage.
If an employee believes or suspects a breach of this Policy has occurred or there is a risk of a breach occurring, they must notify their manager or report it in accordance with our Whistleblowing Policy as soon as possible.
We encourage openness and we will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Any breaches of this policy by employees will be dealt with under our Disciplinary, Grievance and Performance Improvement Policies.
We will establish and implement effective processes to:
- Obtain proof of nationality/right to work from each employee and retain copies of these.
We will provide training on this Policy; any associated processes; and the potential risks we face. This will be included in core induction for new colleagues and will also be available for existing colleagues at regular intervals. In the event that a colleague suspects that a customer may be at risk of modern slavery, they should contact either their manager or report it in accordance with our Whistleblowing Policy.
We will communicate the Policy to all employees.
The Group Board and Executive Leadership Team have overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that it is implemented effectively.
The Governance directorate has primary day to day responsibility for dealing with any queries, investigations and audits of internal control systems and processes.
Managers at all levels are responsible for ensuring that their teams understand and comply with this Policy.
It is the responsibility of the Procurement Team or lead officer to ensure that the Supplier Code of Conduct and contractual arrangements are agreed and implemented with our suppliers, contractors and business partners and that compliance statements are obtained and retained.
This policy will be reviewed at least every three years. People Services will monitor compliance by colleagues. Contract managers/lead officers will monitor supply chain compliance.
We will publish annually on our website a statement which confirms our compliance with this Policy and legislation. It will set out what action we have taken during the year and what steps we intend to take next.
The Group is committed to E,D&I and such will make reasonable adjustments to the policy to recognise, accommodate and support individual needs, where needed.
This Policy adheres to the Group’s approach to Equality and Diversity.
Group members will take a proactive approach to ensure that no individual or group is discriminated against or treated differently as a direct or indirect result of this Policy.
Please note that Appendices A and B are documents for internal use only.
Updated: 08 August 2023