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MODERN SLAVERY STATEMENT

ANTI-SLAVERY POLICY STATEMENT

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This statement is made pursuant to section 54 of the Modern Slavery Act 2015.

 

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.

 

The Charity has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our charity dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own charity or in any of our supply chains.

 

We are also committed to ensuring there is transparency in our own charity 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 from all of our contractors, suppliers and other charity 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 charity partners.

 

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

 

Responsibility for the policy

 

The Charity has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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The Charity has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

 

Trustees and volunteers 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 the issue of modern slavery in supply chains.

 

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to The Trustees via broughtonwmi@gmail.com

 

Compliance with the policy – all stakeholders

 

• As an employee, contractor, supplier or other relevant stakeholder 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 charity 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 a current Trustee of BWMI 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 charity 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 a current Trustee as soon as possible.

• You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own charity and supply chains.

• 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 a current Trustee.

• 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 because 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 charity or in any of our supply chains.

• Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment

• If you believe that you have suffered any such treatment, you should inform a current Trustee immediately. If the matter is not remedied, and you are an employee, you should raise it formally to a current Trustee.

 

Communication & awareness of this policy

 

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and charity partners at the outset of our charity relationship with them and reinforced as appropriate thereafter. This webpage shall constitute communication.

 

Breaches of this policy

 

Anybody who breaches this policy will face disciplinary action, which could result in barring, dismissal for misconduct or gross misconduct.

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We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.