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Anti-slavery and human trafficking policy

1. Policy statement

This policy sets out arrangements to ensure fairness and consistency regarding anti-slavery and human trafficking. The policy applies to all operatives and employees who are either directly employed, sub- contracted or a self-employed basis.


2. Introduction

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure any type of slavery is taking place in our own business.

We are also committed to ensuring transparency in our own business and in our approach to tackling modern slavery. We expect the same standards from all our contractors, sub-contractors, suppliers and other business partners, and as a part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude whether adults or children.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, sub-contractors and self-employed operatives.

This policy doesn’t form any part of an employee’s contract of employment.


3. Responsibility for the policy

The management board has overall responsibility for ensuring this policy complies with both our legal and ethical obligations, and that all those under our control comply with it.

The HR director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and ensuring all procedures are effective in countering modern day slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the HR director.


4. Compliance with the policy

Ensure you have read and understood this policy and ensure you comply with it at all times.

The prevention, detection and reporting of modern slavery in any part of our business is the responsibility of all those working for us or under our control, you are required to avoid any activity that might lead to or suggest a breach of this policy.

You must notify your line manager or HR director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest possible stage.

If you are unsure whether a particular act, treatment of workers more generally or their working conditions within any tier of our supply chains constitutes any various forms of modern slavery, raise it with your line manager or HR director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith any suspicions they may have. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied and you are an employee, you should raise it formally using our grievance procedure which can be found in the employee handbook.


5. Communication and awareness of the policy

All employees, sub-contractors and self-employed personnel undertaking work on our behalf will be made aware of this policy upon starting with the company.

Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.


6. Breaches of the 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 any other individuals such as sub-contractors, self-employed or supply chain on our behalf if they breach this policy.


7. Employees responsibilities

All employees must ensure they read, understand, and comply with this policy. Any employee who breaches this policy will face disciplinary action which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.


8. Key responsibilities

The HR Director has overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under our control comply with it. Management at all levels are responsible for ensuring those reporting to them is made aware and understand this policy.


9. Monitoring and review

The HR Director will monitor the effectiveness and review the implementation of this policy and will regularly consider its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible. All associated with RM Contractors are invited to comment on this policy and suggest ways in which it might be improved. All comments, suggestions and queries should be addressed to the HR Director.

This policy will be reviewed on an annual basis or as and when required.


Signed: Christopher Moen

Position: Managing Director

Policy last updated: January 2022






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