Modern slavery is a serious crime that constitutes a violation of fundamental human
rights. In accordance with the Modern Slavery Act 2015 (the Act), this policy
addresses the offences of slavery, servitude, forced or compulsory labour, and
human trafficking, ensuring that our organisation remains committed to preventing
any form of modern slavery within our business or supply chains.
Definitions of Modern Slavery
Slavery: Defined by the 1926 Slavery Convention, it refers to a condition in
which one person exercises powers of ownership over another, depriving
them of their freedom.
Servitude: Involves a person being forced to provide services through
coercion, without the ability to change their circumstances.
Forced or Compulsory Labour: As defined by the International Labour
Organisation (ILO), this occurs when work is imposed under threat or coercion
and the individual has not voluntarily agreed to it.
Human Trafficking: Refers to the arrangement or facilitation of travel for an
individual with the intent to exploit them, regardless of whether they consent
to travel.
Child Labour: Refers to the exploitation of children under the age of 12 in
economic activities or those aged 12-14 in more than light work, and any child
engaged in the worst forms of child labour.
The Policy
We are committed to combating all forms of modern slavery and ensuring that our
operations and supply chains remain free from such exploitation. This policy applies
to all staff and suppliers we work with.
Compliance Requirements
Under the Modern Slavery Act, commercial organisations in the UK with an annual
turnover above £36 million are required to produce a slavery and human trafficking
statement each financial year. This statement must outline steps taken to prevent
modern slavery within their supply chains. Although our organisation does not meet
the £36 million threshold, we remain committed to transparency and good practice in
addressing modern slavery risks, voluntarily producing a modern slavery statement
to share with partners, suppliers, and commissioners.
Smaller Organisations
Smaller organisations, including ours, are encouraged to take proportionate steps to
address modern slavery risks. We will continue to monitor our suppliers and engage
in practices consistent with the Act’s guidance, including promoting transparency and
due diligence in our recruitment and supply chain processes.
Reporting
All staff have a duty to report any concerns or suspicions about potential modern
slavery to their line manager. In turn, the manager will take appropriate action,
including reporting to the Modern Slavery Helpline (08000 121 700) or via the online
platform: Modern Slavery Helpline.
Related Policies
Related Guidance
Gov.UK: https://www.gov.uk/government/collections/modern-slavery
Transparency in Supply Chains: A Practical Guide:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/64990
6/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf
Modern Slavery Helpline: https://www.modernslaveryhelpline.org/report
Gov. UK A Call to Action to End Forced Labour, Modern Slavery and Human
Trafficking: https://www.gov.uk/government/publications/a-call-to-action-to-end-
forced-labour-modern-slavery-and-human-trafficking
Training Statement
All staff will be provided with training on the Modern Slavery Act and our
organisation’s policies as part of their induction. Ongoing training will be available to
ensure that staff and managers are aware of their responsibilities and are equipped
to identify and report modern slavery concerns.
Approval
This statement was approved by:
Name: Sandra Mononga
Date: Feb 2025
This policy reflects our commitment to ethical business practices, human rights, and
the prevention of modern slavery in all areas of our operations.