Modern Day Slavery Policy

The Modern Slavery Act (MSA) 2015 covers four activities:

Introduction

3-2-1-GoCheck aims to maintain and improve our systems and processes to help eliminate slavery and human trafficking from any part of our business. Currently 3-2-1-GoCheck’s does not have a defined supply chain therefore this policy will not yet be enforceable. The following statement sets out the steps 3-2-1-GoCheck is taking to combat slavery and human trafficking within our business.

This policy covers all four activities listed in Table 1.

How Is implementing Modern Slavery Act Relevant to 3-2-1-GoCheck?
It makes business sense for 3-2-1-GoCheck to help prevent exploitation and human trafficking given it protects both our employees and our reputation. It creates awareness within 3-2-1-GoCheck that as we grow, we need to pay close attention to our supply chain.

Responsibilities
3-2-1-GoCheck, our managers and our colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity. Everyone at 3-2-1-GoCheck must observe this Policy and be aware of its purpose

3-2-1-GoCheck

3-2-1-GoCheck Will:

• Maintain our policies and procedures to help prevent exploitation and human trafficking, and in doing so protect our employees and reputation.
• Be clear about our recruitment policy (Recruitment)
• As we grow, be vigilant with our supply chain and be clear about our expectations regarding the Act

Managers

Managers will:

• Lead by example by making appropriate checks on employees and suppliers to ensure we know who is working for us
• Ensure we have in place an open and transparent grievance process for all staff
• Seek to raise awareness so that our colleagues know what we are doing to promote their welfare
• Make a clear statement that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement)

Colleagues

Colleagues will:

• Listen and be approachable to other colleagues
• Respond positively if they are told a colleague is in an exploitative situation
• Remain alert to indicators of slavery (see Identifying slavery)
• Raise the awareness and ensure all employees are provided a copy of this policy and be aware of their responsibilities
• Use their experience and professional judgement to assess situations that may suggest activities listed in Table 1.

We all have responsibilities under this policy. Whatever the role or level of seniority, you must:

• Report if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery)
• Follow our reporting procedure if a colleague tells you something that may indicate they are or someone else is exposed to items listed in Table 1.

Our Procedures

Anti-Slavery Statement

3-2-1-GoCheck take our responsibilities to our employees, people working within our supply chain and our clients seriously. Part of our responsibility will be to review our policy on a yearly basis.

Supply Chains

We tell the companies we will do business with, we are not prepared to accept any form of exploitation.

We make reasonable requests on our supply chain for them to demonstrate they are not participating in activities listed in Table 1.

Using Agencies

• 3-2-1-GoCheck will its firm policy and only use reputable recruitment agencies.
• We expect all recruitment agencies with whom we engage:
• To fully comply with the Modern Anti-Slavery Act 2015;

General Internal Recruitment

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

Identifying Slavery

There are no typical victims and some victims do not understand they have been exploited and are entitled to help and support.
However, the following signs could indicate that someone may be a slavery or trafficking victim:

• The person is not in possession of their own passport 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.
• 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.

Reporting Slavery

• Talking to someone about your concerns may stop someone else from being exploited or abused
• If you think that someone is in immediate danger, dial 999.
• Otherwise, you should discuss your concerns with the Human Resources Manager who will decide a course of action which may include contacting the Police
• 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, so it is important that in the absence of an immediate danger, you discuss your concerns first with the Human Resources Manager before taking any further action.

Training

We ensure that all employees are made aware of this policy, and their obligation to comply with this policy.

Monitoring Our Procedures

We will review our Anti-slavery policy at least annually and will provide information and/or training on any changes we make.