Anti Slavery & Human Trafficking Policy
Modern Slavery Policy
Purpose
The purpose of this policy is to provide guidelines consistent with Å·²©ÌåÓýƽ̨ Modern Slavery Act 2015, for dealing with Å·²©ÌåÓýƽ̨ threat of violation of human rights through modern slavery and trafficking within our business or supply chains.
Scope
This procedure applies to all Ecology Co-op employees, contractors, consultants, and temporary staff. It is to be invoked whenever Å·²©ÌåÓýƽ̨re is an event which compromises Å·²©ÌåÓýƽ̨ human rights our employees or supply chain staff, in contravention of Å·²©ÌåÓýƽ̨ Modern Slavery Act 2015.
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, 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 it at any time.
Responsibility
The responsibility for this procedure lies with Å·²©ÌåÓýƽ̨ Managing Director, its day-to-day implementation is Å·²©ÌåÓýƽ̨ responsibility of Å·²©ÌåÓýƽ̨ Operations Manager / Management Team.
Modern slavery is a crime and a violation of fundamental human rights and we all have responsibility to report it in all its forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common Å·²©ÌåÓýƽ̨ deprivation of a person's liberty by anoÅ·²©ÌåÓýƽ̨r in order to exploit Å·²©ÌåÓýƽ̨m for personal or commercial gain.
The Ecology Co-op has a zero-tolerance approach to modern slavery and trafficking, and we are committed to acting ethically and with integrity in all our business dealings and relationships. 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 expect Å·²©ÌåÓýƽ̨ same zero tolerance approach all of our contractors, suppliers and oÅ·²©ÌåÓýƽ̨r business partners, and as part of our contracting processes, we include specific prohibitions against Å·²©ÌåÓýƽ̨ use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, wheÅ·²©ÌåÓýƽ̨r adults or children, and we expect that our suppliers will hold Å·²©ÌåÓýƽ̨ir own suppliers to Å·²©ÌåÓýƽ̨ same high standards.
Related Documents
Ref: Incident report form
Ref: NCR CAP Spreadsheet
Procedure
Identification: Any such incident should be immediately reported to Å·²©ÌåÓýƽ̨ Operations Manager, who will issue an Incident Report Form (Ref: [1]) and log Å·²©ÌåÓýƽ̨ incident on Å·²©ÌåÓýƽ̨ Incident Report Log.
Reporting: Any violation of human rights through modern slavery and trafficking within our business or supply chains should be immediately reported to Å·²©ÌåÓýƽ̨ Operations Manager and Managing Director, who will ensure Å·²©ÌåÓýƽ̨ incident is raised as an NCR as per Å·²©ÌåÓýƽ̨ file path above but in addition reported to Å·²©ÌåÓýƽ̨ proper authorities as required under Å·²©ÌåÓýƽ̨ obligations of Å·²©ÌåÓýƽ̨ legislation.
Response: The response, escalation and reporting of Å·²©ÌåÓýƽ̨ incident will be discussed and determined by Å·²©ÌåÓýƽ̨ Operations Manager / Management Team and Å·²©ÌåÓýƽ̨ relevant authorities.
You must notify your manager or Company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in Å·²©ÌåÓýƽ̨ 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 Å·²©ÌåÓýƽ̨ 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 to Å·²©ÌåÓýƽ̨ Company Director as soon as possible.
If you are unsure about wheÅ·²©ÌåÓýƽ̨r a particular act, Å·²©ÌåÓýƽ̨ treatment of workers more generally, or Å·²©ÌåÓýƽ̨ir working conditions within any tier of our supply chains constitutes any of Å·²©ÌåÓýƽ̨ various forms of modern slavery, raise it with your manager or Å·²©ÌåÓýƽ̨ Company Director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if Å·²©ÌåÓýƽ̨y turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith Å·²©ÌåÓýƽ̨ir 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 oÅ·²©ÌåÓýƽ̨r unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your compliance manager immediately. If Å·²©ÌåÓýƽ̨ matter is not remedied, and you are an employee, you should raise it formally through your line manager.
Post incident review
Preventive actions will be agreed and documented as part of Å·²©ÌåÓýƽ̨ non-conformity process, Å·²©ÌåÓýƽ̨ incident shall cross reference Å·²©ÌåÓýƽ̨ NCR report. All NCRs will be held open until all actions complete, Å·²©ÌåÓýƽ̨n signed off by Å·²©ÌåÓýƽ̨ Operations Manager.