Modern Slavery Act Statement

Modern Slavery Policy

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

In 2019 PwC estimated that approximately 40 million people were victims of modern slavery globally, and there were 16 million people forced into labour in the private sector. As competition between industries increases and the desire for ever-lower prices rises; the risk of modern slavery occurring within private organisations and their supply chains may also rise. Modern slavery remains an enormous issue as it can often go undetected in the supply chain of large corporations. 

It is crucially important that companies take a strong stance against modern slavery in their organisation or their partners’ and suppliers’.     

At SPACE&PLACE (S&P) we do everything in our power to ensure that our employees have been recruited through safe and legal means, and thoroughly investigate all our suppliers or any organisation that we partner with, to make certain that no instances of modern slavery are occurring. 

Our Modern Slavery and Human Trafficking policy aims to eradicate all forms of modern slavery and human trafficking within our organisation and ensures that we do not partner with any organisations, suppliers or contractors who do not take their modern slavery preventions seriously. Both our Modern Slavery and Human Trafficking policy and action plan have been created in compliance with the Modern Slavery Act 2015.

The following action plan outlines how we will implement our policy aims.

Action Plan

Scope

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, agents, contractors, and suppliers. All staff are responsible for educating themselves on the signs of modern slavery and human trafficking and the appropriate action to take if they believe it is taking place.  

Whilst all employees are responsible for preventing and eradicating modern slavery in our organisation, there are a few groups who play a crucial role in intercepting this issue. These are primarily those in charge of our recruitment and purchasing process and all managerial staff. Our staff must pay particular attention to the procurement guidance set out by the government in their Procurement Policy Note from 2019 (https://www.gov.uk/government/publications/procurement-policy-note-0519-tackling-modern-slavery-in-government-supply-chains).

Management is accountable for the actions of its staff and therefore must make certain that all employees comply with this policy and have been sufficiently trained regarding modern slavery.

Commitments

At S&P we expect everyone working with us or on our behalf to support and uphold the following values and measures to safeguard against modern slavery.

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

• The prevention, detection, and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
• All staff are required to complete our training materials on the topic of modern slavery and human trafficking so that they can understand and identify the signs and can follow the appropriate procedure of identifying and reporting a case if they ever need to. 

• All staff must be aware of how and where to report an instance of suspected modern slavery. Employees of S&P should be aware of the Modern Slavery helpline and website (08000 121 700 and www.modernslaveryhelpline.org). The helpline provides information and advice about modern slavery, a 24-hour telephone reporting line and there is an online reporting function through the website. If an individual suspects modern slavery is taking place, they can also report it to the police on 101 or in the case of an emergency call 999. If members of staff would like further information relating to modern slavery and how to report it, we advise that they visit the Home Office modern slavery webpages on GOV.uk.

• When reporting instances of modern slavery, the safety of the victim takes top priority, therefore we ask that if staff ever report an incident of slavery they do so after reading through the resources available on the National Crime Agency and government website to guarantee that the crime is reported safely.

• In line with our Sustainable Procurement Policy, we are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

• We require all organisations, suppliers, and contractors that we collaborate with to create and adhere to their own Modern Slavery and Human Trafficking policy and action plan.

• We expect that, if requested, our partners can provide us with:

A copy of their modern slavery statement and action plan; details of how they would investigate any potential incidents; standard immigration and right to work documents of their employees; ID documents of their employees; evidence of staff contracts; evidence that staff are being paid at least minimum wage; details of their employees’ statutory rights and details of how working hours are monitored.

• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

• Consistent with our risk- based approach we may require:

Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct; suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code.

• As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code                of Conduct.

• When carrying out audits we request that our partners and suppliers can provide the following information: 

A copy of their Modern Slavery and Human Trafficking policy; a copy of their Equality, Diversity, and Inclusion policy; a copy of their disciplinary and grievance procedure; a sample of their Health and Safety policy and can produce evidence of their employees’ wages which comply with the government standard and minimum wage requirement.

• If we find that organisations working with us or on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

• We expect any organisation, supplier, or contractor we work with to follow this procedure; therefore, we ask all overseas partners to also comply with our policy and action plan.

• We will make sure to publish a copy of this policy and action plan on our website and our staff           intranet site.

• We have joined the Free for Good campaign which emphasises the importance of creating a safe environment and support system for a victim of modern slavery after their case has been reported. More about this campaign can be found at: https://www.antislavery.org/take-tion/campaigns/protect-victims-slavery-uk/

• Our Modern Slavery and Human Trafficking policy will be reviewed and edited on an annual basis, and we will ensure that we update our policy and action plan where necessary so that it remains compliant with government guidance.

Responsibility

It is the duty of our Human Resource staff and managerial staff to ensure that this policy and action plan is carried out and reviewed on annual basis.

The Modern Slavery and Human Trafficking policy and action plan will be reviewed overall on a yearly basis by our company director Keith Ashton.