Anti-Slavery Policy

Table of Contents
Table of Contents —————————————————————————————————————————————————- 2
Document Details —————————————————————————————————————————————————- 3
Version History ——————————————————————————————————————————————————- 3
Anti-Slavery Policy Statement ———————————————————————————————————————————— 4
Purpose —————————————————————————————————————————————————————– 5
Interpretation ——————————————————————————————————————————————————— 5
Legislation ————————————————————————————————————————————————————- 5
Scope——————————————————————————————————————————————————————– 6
Requirements ——————————————————————————————————————————————————— 6
Reporting ————————————————————————————————————————————————————– 6
Safeguards ————————————————————————————————————————————————————- 8
Review —————————————————————————————————————————————————————— 8
Document Details
Title
Anti-Slavery Policy
Document Reference
06.03
Company
Britannia Safety Ltd
Author
Chris Endicott
Manager
Chris Endicott
Publication Date
16/06/2021
Version History
Version
Details
Author
Manager
Date
01.00
Initial Issue
Chris Endicott
Chris Endicott
16/6/2021
Anti-Slavery Policy Statement
Britannia Safety Ltd is committed to opposing modern slavery in all forms and preventing such by any means available. The same commitment is required of all employees and members of the supply chain, and it is expected that they will familiarise themselves with this policy.
To meet this commitment, Britannia Safety Ltd operates to a set of core principles which reflect the attitude to preventing the exploitation of individuals in any form, and particularly the offences laid down under the Modern Slavery Act 2015.
The person responsible for ensuring the overall effectiveness and implementation of the policy and having accountability is the Managing Partner.
Britannia Safety Ltd will fulfil its obligations by:
• Strictly implementing this Anti-Slavery Policy.
• Adopting a consistent and fair approach to dealing with any report or incident of slavery.
• Reviewing and revising this policy as necessary at regular intervals.
A copy of the SHEQ Management System documentation will be available for all employees, subcontractor workers and consultants to ensure they are aware of the company policies and the responsibilities of all personnel.
This policy and associated procedures will be formally reviewed annually, although on exception, changes may be implemented at other times as required by legislative and work practice changes.
Signed
CJEndicott
Name
Chris Endicott
Title
Director
Date
16/06/2021
Purpose
Modern Slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in many forms, which include:
• Servitude
• Forced or Compulsory Labour
• Human Trafficking
All these forms have in common the deprivation of a person’s liberty by another for the purpose of personal or commercial gain.
The purpose of this policy is to set out the policy of Britannia Safety Ltd with the aim of preventing opportunities for modern slavery to occur within the business or the supply chain.
As a company, Britannia Safety Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and implementing and enforcing effective systems and controls to ensure modern slavery is not present within the business or the supply chain.
Interpretation
In this policy and any associated documents, the following expressions shall bear the meanings defined below:
Expression
Meaning
Modern Slavery
The deprivation of a person’s liberty by another in any form for the purpose of personal or commercial gain.
Employee
Any full or part-time partner, officer, manager, employee, subcontract worker, agency worker or consultant of Britannia Safety Ltd.
Legislation
The key legislation that inputs into this policy is:
• Modern Slavery Act 2015.
Any reference to a statutory provision shall be deemed to include a reference to any modification, substitution, amendment or re-enactment thereof.
Scope
This policy and its requirements apply to all employees, agency workers, subcontract workers and consultants working on behalf of Britannia Safety Ltd, hereinafter referred to collectively as ‘Employees’.
It is expected that all members of the supply chain will also conform with the requirements of this policy where they do not have a specific policy of their own which meets the requirements of the Modern Slavery Act 2015.
Any misconduct on the part of an Employee in relation to modern slavery shall be dealt with as a disciplinary matter. This will very likely result in immediate termination.
Furthermore, all cases of such practices shall be reported to the public authorities unless the Managing Partner decides otherwise.
Requirements
Britannia Safety Ltd is committed to transparency in the business and in the approach to countering modern slavery throughout the supply chain, consistent with the disclosure obligations under the Modern Slavery Act 2015. The same standard is expected from our contractors, suppliers and other business partners, who should additionally hold their own supply chain to the same standards in turn.
All employees are required to familiarise themselves with this policy and assist Britannia Safety Ltd in the identification and prevention of modern slavery and to conduct all business activities in such a manner than the opportunity for modern slavery is prevented.
Whilst Britannia Safety Ltd recognises its statutory obligation to set out the steps to ensure that modern slavery and human trafficking is not taking place in the supply chain, it also acknowledges that it does not control the conduct of individuals and organisations in the supply chain. To underpin compliance with practical steps, Britannia Safety Ltd intends to implement the following measure:
1. Conduct risk assessments to determine which parts of the organisation and which suppliers are most at risk of modern slavery so that efforts can be focused on those areas.
2. Engage with key vendors both to convey to them this Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their own organisations.
3. Where appropriate, undertake supplier pre-screening as part of the vendor assessment process and self-reporting for vendors on safeguarding controls.
4. Introduce contractual provisions for vendors to confirm their adherence to this policy and accept the right of Britannia Safety Ltd to audit their activities and, where practicable, relationships, both routinely and at times of reasonable suspicion.
Reporting
The prevention, detection and reporting of any act of modern slavery is the responsibility of all employees at every level of the business. If any employee becomes aware of or suspects that such activity or conduct has been proposed, is taking place or has taken place in the past then they have a duty to report this.
Specifically, an employee should immediately report any of the following circumstances:
1. Any person either employed by or acting on behalf of Britannia Safety Ltd is seeking to exploit another in such a way which could amount to modern slavery.
2. Any person either employed by or acting on behalf of a vendor of Britannia Safety Ltd is seeking to exploit another in such a way which could amount to modern slavery.
3. An employee has been approached by any person employed by or acting on the behalf of Britannia Safety Ltd or a vendor of such, who has invited them to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed.
4. Information is discovered which suggests that a person employed by or acting on behalf of Britannia Safety Ltd, or a vendor of such, is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.
Any such incident can be reported either to an immediate superior, such as a Supervisor, Line Manager or any other member of the Management Team, or directly to the Managing Partner. Any such report, including the content, shall be treated as strictly confidential.
Safeguards
Openness is encouraged by Britannia Safety Ltd and support will be provided for any person who raises genuine concerns in good faith under this policy, even if they are found to be mistaken. Nobody shall suffer any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery in any form is, or may be, taking place within Britannia Safety Ltd or the supply chain. Detrimental treatment may include dismissal, disciplinary action, threats, or any other unfavourable treatment connected with their raising a concern. Britannia Safety Ltd will accept and take seriously any concerns which are communicated anonymously.
Any claims or allegations made which are found to be malicious or vexatious may result in disciplinary action being taken against the individual.
Review
This Anti-Slavery Policy shall be reviewed either annually, or more frequently if any change in the requirements or activities of the business requires and may be amended from time to time. This review will be carried out by the Compliance Manager and recommendations for change shall be presented to the Managing Partner for adoption into this policy