Modern Slavery and Human Trafficking Policy

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1. Purpose

1.1 The purpose of this policy is to set out the responsibilities of The ID Co. and those who work for us in regards to observing and upholding our zero-tolerance position on modern slavery and human trafficking.

1.2 It also exists to act as a source of information and guidance for those working for The ID Co., helping them recognise and deal with modern slavery and human trafficking, as well as understand their responsibilities

2. Policy Statement

2.1 The ID Co. is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure modern slavery and human trafficking. The ID Co. has zero-tolerance for modern slavery and human trafficking. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 The ID Co. will constantly uphold all laws relating to modern slavery and human trafficking in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Modern Slavery Act 2015, in regards to our conduct both at home and abroad, as well as applicable laws in other countries that we operate.

2.3 The ID Co. recognises that modern slavery and human trafficking are punishable by up to ten years imprisonment and a fine. If our company is found to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing acts of modern slavery and human trafficking in our business and take our legal responsibilities seriously.

3. Who is covered by this policy?

3.1 This modern slavery and human trafficking policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to modern slavery and human trafficking.

4. Definition of modern slavery and human trafficking

4.1 Modern Slavery is a term used to encapsulate both offences in the Modern Slavery Act: slavery, servitude and forced or compulsory labour; and human trafficking. The offences are set out in section 1 and section 2 of the Act, which can be found at:http://www.legislation.gov.uk/ukpga/2015/30/section/1/enacted
http://www.legislation.gov.uk/ukpga/2015/30/section/2/enacted

4.2 Definition of Slavery and Servitude.
Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/she did own the person, which deprives the victim of their freedom. Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her
condition.

4.3 Definition of Forced or Compulsory Labour.
Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily.

4.4 Definition of Human Trafficking
An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or maybe a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that arranging or facilitating the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation. The meaning of exploitation is set out here: http://www.legislation.gov.uk/ukpga/2015/30/section/3/enacted

5. Areas to be monitored for Modern Slavery and Human Trafficking

5.1 Certain areas of our business are more susceptible to the risk of Modern Slavery and Human Trafficking. Additional scrutiny needs to be maintained in these activities and areas

5.2 Supply Chains
We tell the companies we do business with, that we are not prepared to accept any form of exploitation. From the date of this policy, all relevant supplier contracts will contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.

We apply reasonable due diligence to risk assessing our supply chain and use the following mechanisms to do this:

- Supplier mapping initially performed on spend level and then the industry sector to identify key vulnerabilities.
- Risk Assessment of spend areas in relation to the supply chain and their propensity of historically proven risk
- Training and knowledge sharing for key Procurement
- Ensuring all suppliers deemed “at risk” are fully supportive of the aims of this policy,
- If any issues are identified then this is escalated to the senior stakeholders in the business, with all methods of remediation to be available (up to and including exiting the relationship with the supplier)

5.3 Recruitment
The ID Co. help reduce the risk of modern slavery and human trafficking within recruitment by using Agencies that follow the Modern Slavery Act and only uses agreed specified reputable recruitment agencies.

We expect all recruitment agencies with whom we engage:

- To fully comply with the Modern Anti-Slavery Act 2015;
- Are free from ethical ambiguities;
- Are transparent, accountable and auditable.

If the Company has reason to believe that any recruitment agency has failed to meet these standards, HR should be informed and any contracts with them would be terminated.

5.4 General Recruitment
The ID Co.will always ensure:

- All staff have a written contract of employment.
- Ensure staff are legally able to work in the UK.
- Provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

If through our recruitment process, we suspect someone is being exploited, the HR will be informed and the HR department will follow our reporting procedures (See 7.0 What happens if I need to raise a concern).

5.5 Identifying Slavery
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.

However, the following key signs could indicate that someone may be a slavery or trafficking victim:

- The person is not in possession of their own passport, identification or travel documents.
- The person is acting as though they are being instructed or coached by someone else.
- They allow others to speak for them when spoken to directly.
- They are dropped off and collected from work.0.
- The person is withdrawn or they appear frightened.
- The person does not seem to be able to contact friends or family freely.
- The person has limited social interaction or contact with people outside their immediate environment.

Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.

If you have a suspicion, report it to the HR Department who will follow our reporting procedures.

6. Employee Responsibilities

6.1 As an employee of The ID Co., you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other modern slavery or human trafficking information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of the modern slavery or human trafficking policy.

6.3 If you have reason to believe or suspect that an instance of modern slavery or human trafficking has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. The ID Co. has the right to terminate a contractual relationship with an employee if they breach this modern slavery or human trafficking policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:

a. How to raise a concern.
b. What to do if you are a victim of modern slavery or human trafficking

7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to The ID Co., you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered modern slavery or human trafficking, you should speak to your line manager, the compliance manager, HR or a director.

The ID Co. will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

7.3 What to do if you are a victim of modern slavery or human trafficking
If you have any concerns regarding alleged human trafficking or criminal activity in your area, use the following details:

Email the Police Scotland National Human Trafficking Unit: SCDNationalHumanTraffickingUnit@scotland.pnn.police.uk

Modern Slavery Helpline: https://www.modernslaveryhelpline.org/scotland

8. Training and Communication

8.1 The ID Co. will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

8.2 The ID Co.’s modern slavery or human trafficking policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

8.3 The ID Co. will provide relevant modern slavery or human trafficking training to employees etc. where we feel their knowledge of how to comply with the Modern Slavery Act needs to be enhanced. As a good practice, all businesses should provide their employees with modern slavery or human trafficking training where there is a potential risk of modern slavery or human trafficking.

9. Monitoring and reviewing

10.1 The ID Co.’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess their suitability, adequacy, and effectiveness.

10.2
Internal control systems and procedures designed to modern slavery or human trafficking are subject to regular audits to ensure that they are effective in practice.

10.3
Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager or HR.

10.4
This policy does not form part of an employee’s contract of employment and The ID Co. may amend it at any time so to improve its effectiveness at combatting modern slavery or human trafficking.