ANTI-SLAVERY & HUMAN TRAFFICKING POLICY
Fountainlife Hire recognises its responsibilities under section 54 (1) Modern Slavery Act 2015 and is fully committed to taking a robust approach in the prevention of slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.
ORGANISATION’S STRUCTURE
It is intended that this statement covers the activities of Fountainlife Hire in achieving its vision, mission and strategic objectives as determined by its organisational structure.
OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our partnerships or in any part of our business. Our modern slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the business.
ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. To ensure all our partners and suppliers comply with our values we are implementing a comprehensive audit programme. This begins with ensuring that the elimination of any risk of modern-day slavery features in our on-boarding processes and strategic sourcing practices (including sourcing plans and invitations to tender). Where this is deemed to be a potentially significant risk of modern-day slavery practices within our partners/suppliers, we may conduct a mapping exercise, to enable us to determine where the risk exists and determine an appropriate course of action.
In addition, the compliance programme consists of updating contractual templates for new procurements and raising awareness through procurement training for officers.
RESPONSIBILITY FOR THE POLICY
The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Operations Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
All staff are responsible for ensuring those reporting to them.
WHISTLEBLOWING
As part of its commitment to ensuring its own integrity in relation to all aspects of its own working practices, Fountainlife Hire has a clear and comprehensive policy, offering protection and support to individuals reporting on any malpractice which may be affecting a person’s basic human rights or dignity, or otherwise unlawful, within its own organization or among its service users.
FURTHER STEPS
We are committed to improving our practices to combat slavery and human trafficking and will review and continue to keep under review the effectiveness of the steps that we are taking to ensure that there is no slavery or human trafficking in our partnerships. As part of this we intend to take the following further steps to combat slavery and human trafficking:
• Identify and meet any training needs for all staff.
• Develop a set of key performance indicators against which our effectiveness can be monitored and reviewed.
• Ensure our approach is under regular review.
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 31 December 2023.
BREACHES OF THIS POLICY
• Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
• We may terminate our relationship with other individuals and organisations’ working on our behalf if they breach this policy.
MODERN SLAVERY HELPLINE
You can find out more about Modern Slavery, report a suspicion or get help and advice from the Modern Slavery Helpline website. They provide victims, the public, statutory agencies and businesses access to information and support on a 24/7 basis.
REVIEW
This policy will be reviewed on an annual basis or following changes to Government updates and statutory guidance in relation to Covid-19 and company risk assessment policies and processes.
HOW WE EMBED THESE PRINCIPLES
We will continue to embed the principles through:
- providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking ensuring staff involved in procurement activity are aware of and follow https://www.gov.uk/government/publications/procurement-policy-note-0519-tackling-modern-slavery-in-government-supply-chains
- ensuring that consideration of the modern slavery risks and prevention are added to Fountainlife Hire policy review process as an employer and procurer of goods and services continuing to take action to embed a zero-tolerance policy towards modern slavery.
