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Anti Slavery Policy

What is Slavery?
1.1 The Modern Slavery Act (MSA) 2015 covers four activities:

  • Slavery: Exercising powers of ownership over a person.

  • Servitude: The obligation to provide services imposed by the use of coercion.

  • Forced or compulsory labour: Work or services exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.

  • Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation.

1.2 This policy covers all four activities.

How is it Relevant to Us?
2.1 Modern slavery is a complex and multi-faceted crime that requires collective efforts to combat. Preventing exploitation and human trafficking while protecting our workforce and reputation is essential.

2.2 The MSA 2015 recognises the role businesses can play in tackling slavery and encourages proactive engagement.

2.3 We pay particular attention to:

  • Our supply chain.

  • Any outsourced activities, particularly in jurisdictions with inadequate safeguards.

  • Cleaning and catering suppliers.

  • Corporate hospitality.

Responsibilities
3.1 Valenti Recruitment, our managers, and colleagues have responsibilities to ensure fair treatment and dignity for all workers.

3.2 Everyone must observe this policy, and turning a blind eye is unacceptable.

3.3 The Company
We will:

  • Maintain clear policies and procedures to prevent exploitation and human trafficking.

  • Implement a transparent recruitment policy.

  • Monitor our supply chains.

  • Conduct due diligence on employees, recruitment agencies, and suppliers.

  • Ensure an open and transparent grievance process for all staff.

  • Raise awareness about modern slavery prevention.

3.4 Managers
Managers will:

  • Be approachable and listen to colleagues.

  • Respond appropriately to concerns regarding exploitation.

  • Stay alert to signs of slavery.

  • Raise awareness through discussions and training.

  • Use their judgment to assess potential risks.

3.5 Colleagues
All employees must:

  • Stay vigilant and report suspicions of exploitation.

  • Follow reporting procedures if they suspect slavery or human trafficking.

  • Suggest improvements for preventing exploitation.

The Risks
4.1 The primary risk areas related to slavery and human trafficking include:

  • Supply chains.

  • Recruitment through agencies.

  • General recruitment processes.

4.2 These risks are managed through the procedures in this policy.

Our Procedures
5.1 Anti-Slavery Statement
5.2 Supply Chains

  • We thoroughly assess supply chains to reduce slavery risks.

  • Our supplier contracts include an anti-slavery clause.

  • We maintain transparency in our supply processes.

5.3 Recruitment
5.3.1 Using Other Agencies

  • We only engage with reputable recruitment agencies.

  • We conduct background checks and verify reputations.

  • Agencies must provide assurances regarding staff compliance with legal requirements.

  • We review approved agencies at least every three years.

5.3.2 General Recruitment

  • We ensure all staff have written employment contracts and have not paid fees for work.

  • We verify the legal right to work in the UK.

  • We monitor employee details for potential indicators of exploitation.

  • We provide new recruits with information on statutory rights and benefits.

Identifying Slavery
6.1 There is no single profile of a victim, and many do not realise they are being exploited.

6.2 Signs of slavery may include:

  • Lack of possession of personal identification or travel documents.

  • Being coached or controlled in conversations.

  • Limited social interaction or freedom of movement.

  • Fearful or withdrawn behavior.

  • Being collected and dropped off at work.

6.3 This list is not exhaustive, and suspicions should be reported.

Reporting Slavery
7.1 Reporting concerns may help prevent further exploitation.

7.2 If someone is in immediate danger, call 999.

7.3 Otherwise, report concerns to the designated individual [Insert Name and Contact Details].

7.4 Discretion is essential to avoid putting victims at risk; discuss concerns before taking action.

Training
8.1 Specialist training is provided to staff managing recruitment and supply chains.

8.2 General awareness training is available to all employees.

Monitoring Our Procedures
9.1 We review our Anti-Slavery Policy annually and update training accordingly.

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