Modern slavery prevention statement
This Policy is made pursuant to the Modern Slavery Act 2015 and sets out the steps that The Welsh Contact Centre Forum has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour and The Welsh Contact Centre Forum has a zero tolerance approach to any form of modern slavery.
The Welsh Contact Centre Forum is committed to acting ethically and with integrity and transparency in all aspects of its business activities. Further we are committed to putting in place appropriate systems and controls to safeguard against any form of modern slavery taking place within our business or our supply chain.
The Modern Slavery Act
The Act provides law enforcement with the tools to fight modern slavery, ensure perpetrators can receive suitably severe punishments for these appalling crimes and enhances support and protection for victims. The Act received Royal Assent 26 March 2015.
– consolidates and simplifies related offences into a single act
– ensures that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences)
– enhances the court’s ability to put restrictions on individuals where it’s necessary to protect people from the harm caused by modern slavery offences
– creates an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery
– introduces a defence for victims of slavery and trafficking
– places a duty on the Secretary of State to produce statutory guidance on victim identification and victim services and to make regulations relating to the identification of and support for victims
– makes provision for independent child trafficking advocates
– introduces a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
– enables law enforcement to stop boats where slaves are suspected of being held or trafficked
– requires businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains
– Slavery continues to occur in many countries and encompasses a wide range of offences.
– Forced labour: any work or services which people are forced to do against their will under the threat of some form of punishment.
– Debt bondage or bonded labour: when people borrow money they cannot repay and are required to work to pay off the debt, then losing control over the conditions of both their employment and the debt.
– Human trafficking: involves transporting, recruiting or harbouring people for the purpose of exploitation, using violence, threats or coercion.
– Descent-based slavery: where people are born into slavery because their ancestors were captured and enslaved; they remain in slavery by descent.
– Child slavery: child slavery occurs when a child’s labour is exploited for someone else’s gain and can include child trafficking, child soldiers, child marriage and child domestic slavery.
– Forced and early marriage: when someone is married against their will and cannot leave the marriage. Most child marriages can be considered slavery.
Someone is in slavery if they are:
– Forced to work: through coercion, or mental or physical threat
– Owned or controlled by an ’employer’ through mental or physical abuse or the threat of abuse
– Dehumanised, treated as a commodity or bought and sold as ‘property’
– Physically constrained or have restrictions placed on their freedom of movement
Obligations under the Act
Businesses within certain criteria are required to disclose each year what action they have taken to ensure there is no modern slavery in their business nor within their supply chains.
– Commercial organisations: i.e. a business or partnership (whether incorporated or formed in the UK) which carries on a business or part of a business in the UK.
– Supplier of goods or service: and total annual turnover of not less than £36 million: includes the turnover of subsidiaries and applies to global and not just UK turnover.
Pursuant to s.54 of the Modern Slavery Act The Welsh Contact Centre Forum has issued a compliance statement which sets out the steps that The Welsh Contact Centre Forum has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
Potential areas of risk
Our supply chain is largely limited to service provision and all suppliers are required to comply with all relevant regulatory and legislative obligations, including the provisions of the Modern Slavery Act 2015.
Our compliance protocols and operating policies
We operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:
1. Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
2. Statement of Corporate Responsibility. This statement promotes corporate responsibility throughout the supply chain.
3. Procurement Policy. This policy outlines the practices and procedures relating to all supply contracts, including the importance of selecting suppliers carefully and in accordance with due diligence requirements, including corporate social responsibility.
4. Recruitment policy. The Welsh Contact Centre Forum operates a robust recruitment policy to safeguard against human trafficking or individuals being forced to work against their will.
5. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
6. Modern slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify risks and where they can go for help.
The Welsh Contact Centre Forum promotes corporate responsibility throughout its supply chain, including the support of human rights The Welsh Contact Centre Forum procurement policy outlines the importance of selecting suppliers carefully; completing due diligence checks to confirm authenticity and ensure that there is no record of adverse performance or poor practice.
Suppliers to The Welsh Contact Centre Forum UK are required to complete a vendor information registration which prompts confirmation from the supplier that their business operations are conducted in accordance with the obligations of the Modern Slavery Act 2015, and, if so required, has published a Modern Slavery Statement
Aside from clear red flags highlighted by negative responses to due diligence tests, potential instances of Modern Slavery can be difficult to spot.
Nevertheless employees, and particularly those involved in procurement activities must be alert to potential offences and in the event of a possible breach becoming apparent should actively raise concerns by following the steps set out below.
In most cases an employee should raise any concerns relating to potential modern slavery offences by speaking to their line manager. If it is not possible to speak to the manager, or if the employee feels uncomfortable to raise the matter with them, the employee should contact Human Resources (HR Business Partner).
The Manager / HR Business Partner will investigate the concern and if necessary, escalate the investigation to the next level manager. Where a credible breach is identified the manager will inform the compliance officer who will determine action required which may include referral to external authorities. In case of dispute, the complaint may be referred to the Country Director, whose decision is final.
The whistleblowing procedure is also available should circumstances warrant.
The Company’s Whistleblowing Procedure is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner. The Whistleblowing Procedure applies to employees and may be found in the Human Resources section of the Company’s intranet site.
In the case of an offence / potential offence involving a counterparty, it is likely that the supply contract will be suspended pending formal investigations (by the relevant party, which may include law enforcement). In the case of a proven offence the supply contract will be terminated. In the unlikely event that an offence involves an employee of The Welsh Contact Centre Forum the Welsh Contact Centre Forum Disciplinary Policy will be triggered.
Education and Information
The Welsh Contact Centre Forum engages all employees in education and provides relevant information relating to compliance and code of conduct. The Modern Slavery Policy has been brought to the attention of employees and the context and relevance explained via the Company’s intranet.
The Welsh Contact Centre Forum 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 when:
– Relevant education and information have been provided
– Counterparty / vendor agreements confirm compliance (with Modern Slavery Policy)
– Recruitment procedures preclude inappropriate practices
– No reports are received from employees, the public, law enforcement agencies or any other parties which might indicate that modern slavery practices have been identified.