Modern Slavery Act 2019
Modern slavery and human trafficking policy statement 2019
Introduction from the Managing Director
Modern slavery is a crime and a violation of fundamental human rights that takes various forms. These forms include 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. We abhor these practices and are committed to improving our practices to combat slavery and human trafficking. We refuse to trade with any organisation which does not have a comprehensive modern slavery policy and will not supply any product which does not have a provable ethical origin. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending April 2019.
The Co-operative, its supply chains and members
Ethstat Ethical Stationery CIC is a provider of facility management supplies across the United Kingdom. The CIC’s supply chain is complex and encompasses a number of global suppliers. However, by the nature of our procurement policy, the overwhelming majority of the products we source are from within the European Union and have auditable employment, union and anti-slavery policies. Where products are sourced from outside the EU, we ensure that the factories have auditable employment, unionisation and anti-slavery policies.
As a Community Interest Co-operative we are aware that we have a special ethical responsibility and that our customers are also members of the company. For this reason we have a responsibility to audit our members with the same rigour as our suppliers.
- Our policies on slavery and human trafficking
Ethstat Ethical Stationery CIC operates the following policies which describe our approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in our operations.
- Whistleblowing policy:
Ethstat Ethical Stationery CIC encourages all staff, customers and other business partners to report any concerns related to the activities, or the supply chains of, the CIC. This particularly includes any circumstances which may give rise to an enhanced risk of slavery or human trafficking. The CIC’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
- Supplier code of conduct:
Ethstat Ethical Stationery CIC is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- The CIC works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the CIC’s supplier code of conduct will lead to the termination of the business relationship. Any supplier found in breach of the code of conduct in relation to slavery and human trafficking will be reported to any relevant authorities immediately.
- Supplier assessment audit: Ethstat Ethical Stationery CIC has put in place a supplier assessment programme to ensure that suppliers can demonstrate compliance with all relevant legislation and our Supplier Code of Conduct.
- Ethical Strategy: The CIC’s approach to purchasing has a direct impact on the lives of people all over the world, and we are therefore committed to doing business in a way which ensures that everyone in our supply chain benefits from trading with us.
- Ethical Risk Assessment: The CIC undertakes a register of ethical risks. This risk register is presented and reviewed at the Annual General Meeting. These include the anti-slavery policy.
in Our Supply Chain
Our suppliers
The CIC operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery, and on-site audits (where relevant) which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- They pay their employees at least the national minimum wage/national living wage or its applicable standard if not from the UK.
- We may terminate the contract at any time should they fail to maintain these standards
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies, to indicate that modern slavery practices have been identified.
Responsibilities
Responsibility for the CIC’s anti-slavery initiatives lies with the managing board and is a set agenda item at all meetings. At the Annual General Meeting, a report on all policies and the ethical risk assessment will be reviewed.
in Our Supply Chain
Our Suppliers
The CIC operates a supplier policy and maintains a preferred supplier list.
We conduct due diligence on all suppliers before allowing them to become a preferred supplier.
This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery, and on-site audits (where relevant) which include a review of working conditions.
Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- They pay their employees at least the national minimum wage/national living wage or its applicable standard if not from the UK.
We may terminate the contract at any time should they fail to maintain these standards.
OUR PERFORMANCE INDICATORS
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies, to indicate that modern slavery practices have been identified.
RESPONSIBILITIES
Responsibility for the CIC’s anti-slavery initiatives lies with the managing board and is a set agenda item at all meetings. At the Annual General Meeting, a report on all policies and the ethical risk assessment will be reviewed.
Anti-slavery and human trafficking policy statement
Modern slavery is a crime and a gross 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. We 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 control 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 obligations in the Modern Slavery Act 2015. We expect the same high standards from all our suppliers, contractors and other business partners. We include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and expect our suppliers to hold their suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including all employees, directors, officers, agency workers, contractors and consultants.
Responsibility
The board has overall responsibility for ensuring the policy complies with our legal obligations and that it is complied with. The company secretary is responsible for implementing the policy and monitoring its use.
Compliance
Everyone issued with the policy must confirm they have read and understood the policy. It is everyone’s responsibility to ensure the prevention, detection and reporting of modern slavery either in the business or supply chain. All of our team are responsible for ensuring that we avoid any activity that may breach or lead to a breach of this policy.
If you have any concerns, please notify your manager, HR or the company secretary as soon as possible. In accordance with the whistleblowing policy, we will ensure that everyone feels comfortable in raising concerns without a risk of any detrimental treatment. Please refer to the whistleblowing policy for more information.
Bruce Halai-Carter
Founder and CEO
