Modern Day Slavery Policy Statement
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that SceneSafe Holdings Ltd has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Group has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the Company or our supply chain.
Our Policies on Slavery and Human Trafficking
The Group is aware of our responsibilities towards clients, service users, employees and the local community and expects all suppliers to the Group to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.
Agreements with our supply chain partners contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with this policy.
We operate a number of internal practices which ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment - We operate a robust recruitment policy, including conducting eligibility to work in the United Kingdom checks for all directly employed staff. DBS Security checks and DNA samples which are uploaded onto the National Database and searched for existing profiles.
- Supply Chain Partners on approved frameworks or service level agreements are audited to provide assurance that pre-employment clearance has been obtained for both permanent and agency staff, to safeguard against human trafficking or individuals being forced to work against their will
- Equal Opportunities - We have a range of controls to protect staff from poor treatment and/or exploitation, which complies with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and fair access to training and development opportunities
- Whistleblowing - We operate a whistleblowing/raising concerns policy so that everyone in our employment knows that they can raise concerns about how colleagues, clients and service / supply chain partners are being treated, or about practices within our business or supply chain, without fear of reprisals, and the various ways in which they can raise their concerns.
- Standards of ethical business conduct - This separate policy document explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our QED 302 supplier assessment questionnaire selection criteria / processes which includes a section on Modern Day Slavery.
- Randomly request that the main contractor provide details of its supply chain.
- Ensuring any call off or service level agreement documents also contains clauses giving us the right to terminate any agreement for failure to comply with labour laws.
- Supplier adherence to our values. We are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit.
- Where it is verified that a supply chain partners subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded from any future dealings we may have.
Training
Advice and training about modern slavery and human trafficking forms part of our mandatory staff induction programme and staff capability reviews. We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.
Our Performance Indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if there are no reports received from our staff, the public, suppliers, law enforcement and other government agencies we deal with to indicate that modern slavery practices have been identified. Tier One suppliers, as part of their annual assessment to remain on our Core Supplier Database will also have to reaffirm that the modern slavery safeguards have been reviewed (at least annually) and provide details of any amendments to the procedures.
For SceneSafe Holdings Ltd
Mike Hopson
Group Managing Director