ANTI-SLAVERY POLICY

INTRODUCTION

Modern slavery is a crime resulting in despicable abuse of human rights. The Modern Slavery Act (MSA) 2015 came into force as from March 2015 and consolidates slavery and trafficking offenses. It covers four activities:
• Slavery;
• Servitude;
• Forced or compulsory labour;
• Human trafficking.
It ensures that offenses are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002. The National Crime Agency, the police, and other law enforcement agencies have the powers to bring to justice those engaged in human trafficking and slavery. Modern slavery is a complex and multi-faceted crime and tackling it requires all partners and staff of Navis International Trade And Consulting Ltd ("the Firm") to play a part. Protecting the workforce and reputation is vital. The MSA 2015 highlights the important need for businesses, and therefore the Firm, to play a part in tackling slavery.

The Transparency in Supply Chains Clause which came into force in October 2015 requires organisations with a turnover of £36m or more to report on processes and due diligence taken to ensure that their supply chains are slavery-free, and to produce and publish a slavery and human trafficking statement each financial year.

RISK

The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to the following Business Partners:
• Supply chains;
• Outsourced activities.

The Firm will manage these risks through the procedures set out in this policy.

RESPONSIBILITIES

 

The Firm, all employees and members have a responsibility to ensure all colleagues and Business Partners are safeguarded, treated fairly and with dignity. This policy must be observed and any serious concerns which are raised will be dealt with as appropriate and may trigger the Firm's disciplinary procedures.
The Firm will:
• maintain clear policies and procedures preventing exploitation and human trafficking, protecting our colleagues, Business Partners and our reputation;

• be clear about the recruitment policy (see Recruitment);
• check the supply chains (see Supply chains);
• make appropriate checks on all employees, recruitment agencies, suppliers, etc.;
• have in place an open and transparent grievance process for all staff.
Supervisors and Line-Managers will:
• listen and be approachable to colleagues;
• respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;
• remain alert to indicators of slavery;
• raise awareness by discussing issues and providing training;
• use their experience and professional judgement to gauge situations.
Colleagues must:
• follow the reporting procedure (see Reporting) if there is any suspicion of a colleague or someone in our supply chain being controlled or forced by someone else to work or provide services;
• follow the reporting procedure if a colleague tells them something that may indicate they are or someone else is being exploited or ill-treated.

ANTI-SLAVERY STATEMENT

The Firm will make a clear annual statement which will show a summary of the steps we have taken during the financial year to ensure that slavery and human trafficking are not taking place in any part of the business or our supply chains. It will be published on our website at the end of each financial year.

It is expected to build on its statement each year and therefore show that improvements can be made.
The statement will also show:
• it's business and supply chains;
• its  policy in relation to slavery and human trafficking;
• the due diligence processes in relation to slavery and human trafficking;
the parts of the business and supply chains where there is a risk of slavery and human trafficking, and what steps are being taken to assess and manage that risk;
• training to be made available to partners and colleagues about slavery and human trafficking. 
The statement will be approved by the members and signed by a designated member. The Firm will publish the statement on its website.

 

RISK ASSESSMENT

 

• To investigate;
• Employment;

• Sector;
• Relationship;
• To investigate the supply chains (a supplier is any individual or company which provides goods or services); 
• We (the Firm) will thoroughly check supply chains to ensure the potential for slavery and human
trafficking is significantly reduced (see supplier questionnaire);
• We will inform companies that we do business with that we are not prepared to accept any form of exploitation;
• Each step of the supply process will be accounted for. We will know who is providing goods and services to us, and we will have mechanisms and processes in place to check, including.


RECRUITMENT USING AGENCIES

 

HR will follow the Firm's policy and only use agreed specified reputable recruitment agencies;
Recruitment agencies will be checked to reduce the potential for slavery and human trafficking, and placed on our list of approved agencies. This will be achieved by:
• Conducting background checks;
• Investigating reputation;
• Ensuring supplied staff have the appropriate paperwork;
• Ensuring assurances are provided by the agency that the appropriate checks have been made on the supplied person(s);
• The list of approved recruitment agencies will be reviewed at least every three years.

 

RECRUITMENT USING AGENCIES

HR will follow the Firm's policy and only use agreed specified reputable recruitment agencies;
Recruitment agencies will be checked to reduce the potential for slavery and human trafficking, and placed on our list of approved agencies. This will be achieved by:
• Conducting background checks;
• Investigating reputation;
• Ensuring supplied staff have the appropriate paperwork;
• Ensuring assurances are provided by the agency that the appropriate checks have been made on the supplied person(s);
• The list of approved recruitment agencies will be reviewed at least every three years.

GENERAL RECRUITMENT

• All staff will have a written contract of employment and will not be asked to pay any direct or indirect fees to obtain work;
• The Firm will ensure staff are legally able to work in the UK;
• Names and addresses of staff will be checked to identify a high number sharing occupancy (often a factor for those being exploited);
• Information will be provided to all new recruits on their statutory rights including sick pay, holiday pay, and any other benefits they are entitled to;
• HR will follow the Firm's reporting procedure should they suspect someone is being exploited.

GENERAL RECRUITMENT

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim. The person:
• may not be in possession of their own passport, identification or travel documents;
• will allow others to speak for them when spoken to directly;
• will be withdrawn or appear frightened;
• does not seem to be able to contact friends or family freely;
• has limited social interaction or contact with people outside their immediate environment.
A person may display a number of the indicators as set out above but they may not necessarily be a victim of slavery or trafficking.

REPORTING
 

If you have any concerns, you should raise them with the Firm's Money Laundering Reporting Officer (MLRO), Mr. Andrej Kudriasov who will decide a course of action and provide any further advice. If you believe the victim may be in immediate danger, please dial 999. Please be aware though, that not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk.
It is therefore important that in the absence of immediate danger, you should discuss your concerns first with the MLRO before taking any further action.

CLAUSE EXAMPLE

Modern Slavery. You hereby affirm your compliance with the Modern Slavery Act 2015 and associated guidance. You confirm (a) that you have read, are familiar with and shall not perform an act or omission which is in contravention with, the letter or spirit of the Act; and (b) you carry out regular, meaningful and comprehensive due diligence procedures and have internal policies in place to address any suspected human rights abuse in your business and Group where applicable.

Modern Slavery - The Supplier must:
•    comply with all applicable laws, statutes, regulations and codes relating to modern slavery or human trafficking, including the Modern Slavery Act 2015; and
•    take reasonable steps to ensure that there is no modern slavery or human trafficking in any part of its business or supply chains.
•    The Supplier represents and warrants that the Supplier has not, nor, to its reasonable knowledge, its officers, employees or others associated with it, been convicted or investigated for modern slavery or human trafficking offences.
•    The Supplier must promptly report to the Purchaser any actual or suspected slavery or human trafficking in a supply chain in connection with this agreement.
•    The Supplier must maintain complete records evidencing its compliance with this clause and grants the Purchaser the right to audit the Supplier for compliance with this clause.