Anti Slavery Policy
Introduction
Modern slavery and human trafficking are crimes that affect communities and individuals across the globe. We are fully committed to playing our part in eradicating modern slavery by strictly prohibiting the use of forced labour and human trafficking within our organisation and supply chains.
The scope of the is policy is all companies within the Jensten Group, both regulated or non-regulated.
The following outlines how we adhere to the Modern Slavery Act 2015 (the “Act”) and confirms our strategy and the steps we take to ensure that there are no occurrences of modern slavery or human trafficking within our organisation or supply chains.
We are also committed to the ongoing review of our practices to ensure we continue to meet the requirements of the Act.
Our strategy
Our strategy is to identify and prevent potential modern slavery and human trafficking risks in our organisation and implement processes, effective systems and controls to mitigate these.
Where risks are identified these will be managed in accordance with the Risk Management Framework. We will record any risks identified and mitigation in our central risk register and these will be reviewed by our Risk & Compliance team on a quarterly basis.
Our risks and approach to mitigation
Our culture
It is a fundamental core value of Jensten to conduct our business with integrity and our employee value proposition has been shared with all our employees and is included in the induction for new employees. We expect everyone who works for us to act with the highest ethical standards.
We have a Whistle Blowing policy in place that actively encourages the reporting and exposure of unethical behaviour. We have a Disciplinary policy in place to address any conduct and behaviour issues.
Pay and conditions
Our employees are all based in the UK and are paid at least the UK National Minimum Wage or Living Wage.
We have a Grievance policy in place to allow employees to voice any concerns about pay and conditions. We have also implemented engagement champions across our business to drive an inclusive and supportive environment where people feel they can raise any concerns and be listened to.
Line Manager Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and to raise awareness of this issue we include information in our line management induction training.
We have introduced management expectations and we have implemented these across our organisation. We expect our line managers to act with the highest integrity and will address any issues through our Disciplinary policy.
M&A activity
We include questions regarding adherence to the Act in our due diligence during any M&A discussions. We will only consider partnering or merging with organisations that have values aligned to ours and where we have concerns about their approach to employee welfare we will suspend any M&A activity.
Responsible recruitment
We ensure any risks of modern slavery or human trafficking are identified during our recruitment process. Our recruitment team are fully trained to manage any safeguarding issues. Any concerns will be highlighted to the Group People Director and a plan of action to address will be agreed.
We will only partner with ethical recruitment agencies and will require confirmation of their adherence to the Act before we agree to sign a contract. We will also only work with recruitment partners such as job boards where again we have confirmation of their adherence to the Act.
Third party suppliers
We have a zero-tolerance approach to modern slavery and human trafficking and will only work with third party suppliers that are aligned to our values.
We will ask all third party suppliers to confirm they adhere to the requirements of the Act at contract stage.
Within our procurement contracts we have included a clause that requires suppliers to confirm they are fully compliant with the Act.
Where no assurance can be given or where we have concerns about ethical approach we will engage with those suppliers at the contract stage and determine whether the risks are high and whether we want to continue with the contract discussions and the relationship.
We review supplier performance and contracts annually and if any risks and concerns are raised we will ask the supplier to complete a review. We will ask them to confirm how they are mitigating any risks associated with modern slavery and human trafficking. If we are not satisfied with their approach we will consider terminating the contract.
Reporting any concerns
We reserve the right to take action against an employee or a third party supplier where we have concerns about non adherence to the Act. We will report our concerns to the Modern Slavery Helpline and/or the police. In an emergency situation where we are concerned about the welfare of an individual we will call 999.
We encourage our employees to raise any concerns with their line manager in the first instance and also report the issue to the HR team. Alternatively our employees can follow the procedure in our Whistle Blowing policy to share any issues they have identified in the organisation.
We commit to investigating any concerns raised as soon as possible and will agree a plan of action to address and mitigate any risks identified.
Record Keeping
We may need to process or retain personal data about our employees in relation to this policy and we will process this data in accordance with the Data Protection Act, further information is provided in our HR Data Protection policy.