- Policy Statement
Modern Slavery is a crime and 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. A&E Elkins Ltd have a zero-tolerance approach to modern slavery and 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 supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards for 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.
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, interns, agents, contractors, external consultants, third party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend at any time.
- Responsibility for the Policy
The Directors of the business has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
This Managing Surveyor as main procurement agent for the Sub-Contractor base has primary and day-to-day responsibility for ensuring that this policy is effectively communicated with third parties to the business. Additionally, they will be responsible for any queries about it, auditing internal control systems and procedures to ensure they are effective in the control of countering modern slavery.
Line managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and issue of modern slavery in supply chains.
Any member of the A&E Elkins team is able to comment and make suggestions of how the policy may be improved. Comments and suggestions are encouraged and should be addressed to the Managing Surveyor or the HR Manager.
- Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
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 supply chains of any supplier tier 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 chain constitutes any of the various forms of modern slavery, raise it with your manager, the Managing Surveyor or the Human Resources 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 supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
- Communication and awareness of this policy
This policy will be distributed to all employees, associates and subcontractors.
A zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of the business relationship; it will be reinforced regularly thereafter.
Breaches of this policy will be dealt with in the appropriate manner.
Any employee who fails to observe or breaches this policy will face disciplinary action; sanctions can include and be up to dismissal.
We may terminate any business relationship with any third party if there is a known breach of this policy.
This policy will be updated in line with legislative change.