Purpose
This policy sets out the Agency’s commitment to ensure compliance with the Modern Slavery Act 2015 (“the Modern Slavery Act” or “the Act”).
It provides guidance to all staff, clients and suppliers as part of the compliance with Modern Slavery legislation, to ensure that all directors, managers, employees or third party agents adhere to the Act.
Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our suppliers.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our suppliers, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Modern slavery can take various forms, including:
• Human Trafficking: the process of trapping people through the use of violence, deception or coercion and exploiting them for financial or personal gain.
• Forced Labour: any work or service which people are forced to do against their will, under threat of punishment. Almost all slavery practices contain some element of forced labour.
• Bonded Labour: also known as debt bondage or debt slavery, it occurs when a person is forced to work to pay off a debt. They are tricked into working for little or no pay, with no control over their debt.
• Child Slavery: the enforced exploitation of a child for someone else’s gain, meaning the child will have no way to leave the situation or person exploiting them.
• Child Marriage: this can be referred to as slavery if the child has not genuinely given their free and informed consent to enter the marriage, if they are subject to control in the marriage (particularly through abuse and exploitation), or if they cannot realistically leave or end the marriage.
• Descent-based Slavery: where people are born into slavery because their ancestors were captured into slavery and their families have ‘belonged’ to slave-owning families ever since.
• Domestic Slavery: domestic workers in private homes where the circumstances and conditions of their work amounts to slavery e.g. their employer stops them from leaving the house, doesn’t pay their wages, uses violence or threats, withholds their identity documents, limits their contact with family and forces them to work.
Policy
As an organisation operating in the UK, No. 8 must be aware of, and ensure its compliance with, the Modern Slavery Act.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or suppliers at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our suppliers. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our Handbook.
Responsibility for Adoption and Implementation by No.8
This Modern Slavery and Human Trafficking Policy requires all No.8 staff to:
• read and understand the mandates set out in it;
• comply with the mandates;
• report immediately actual or suspected violations to your manager.
Breaches of Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Where to get Help
If you have any questions about this Modern Slavery and Human Trafficking Policy, please reach out to your manager. If you believe that the Modern Slavery and Human Trafficking Policy may have been violated, you should immediately contact your manager.