1.1 “Modern slavery” is a term which covers slavery (where ownership is exercised over a person); servitude (which involves the obligation to provide services imposed by coercion); forced or compulsory labour (which involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself voluntarily); and human trafficking (which concerns arranging or facilitating the travel of another with a view to exploiting them, even where the person consents to the travel). Modern Slavery may also be associated with the worst forms of child labour
1.2 We will ensure that we will comply with the Modern Slavery Act 2015 and are putting strict measures in place to ensure that modern slavery is not part of any of our business operations. This includes our supply chains, goods and services. This statement sets out the steps we are taking to continually develop our procedures and to check our compliance.
1.3 This statement covers our financial year ending March 2020.
2.1 We work closely with our main suppliers, customers; and with our employees to ensure the highest level of compliance with ethical trading initiatives.
3.1 The Board of Directors of Central Facilities Group is responsible for overseeing our efforts to help to eliminate modern slavery and for monitoring progress against the key performance indicators (KPIs) contained in this document.
3.2 The HR department and our managers are responsible for ensuring that all recruitment and terms and conditions of employment comply with statutory requirements, and that any agencies used are appropriately checked and commit to ethical standards.
3.3 Managers are responsible for upholding our “core values” and for ensuring that employees who work for them also behave in accordance with these.
4.1 We have the following policies in place for employees:
- Business ethics and integrity policy
- Grievance policy
- Equal opportunity policy
- Recruitment and selection policy
- Whistleblowing policy
4.2 These are referenced in our Employee Handbook.
4.3 Employees are reminded of the policies from time and time and notified of any updates.
5.1 We consider that the main areas of risk of modern slavery within our business and supply chain are forced labour.
6.1.1 We have taken the following specific actions as part of our drive to eliminate modern slavery. Any employee who has any further suggestions regarding actions that may assist us in our overall aim, or concerns about areas of potential risk, should raise these with their manager or any director.
6.2.1 Our recruitment and selection policy aims to assist all those involved in the recruitment process to comply with equal opportunity.
6.2.2 All new employees are recruited directly, and we conform to the ethical standards. Right to work checks are conducted prior to joining, and we check with all new recruits that they have not been required to pay any fees to gain work with us, and inform them of the procedures that should be followed should they wish to leave our employment.
6.3.1 We also work closely with our major customers to ensure optimum environmental friendliness and to ensure that our practices and procedures are in line with national standards.
7.1 If a supplier is found to be involved in any form of modern slavery, its contract will be terminated either immediately or on its due renewal date, depending on the severity of the breach. We may also report any suspicions of criminal activity to the police.
7.2 If the breach is a minor one, we commit to helping that supplier by providing guidance and support for the affected workers.
7.3 If it is established that any employee has acted in breach of any of our policies, or is aware of, has condoned or failed to report any suspicion of modern slavery within our business or supply chains, they will be subject to our disciplinary procedure.
Name: Samantha Robinson
Office held: Director