Purpose of Policy
The aim of this policy is to provide details of the Institute’s rules regarding modern slavery, servitude, forced or compulsory labour, people trafficking, and exploitation to ensure a consistent approach and that the Institute is in line with current employment legislation.
This policy applies to all HDR UK staff, including contractors, secondees and temporary members of staff. This policy also extends to any organisation that we look to enter into a business relationship with.
It is our policy to conduct all business in an honest and ethical manner. It is also our policy not to enter into a business relationship with another person or business whose practices involve slavery or forced labour. We take a zero-tolerance approach to modern slavery and any associated actions, and are committed to acting professionally, fairly and with integrity in all their business dealings and relationships.
What is slavery?
Modern slavery is a complex crime that takes many different forms. It encompasses slavery, servitude, forced and compulsory labour, and human trafficking. Traffickers and slave drivers coerce, deceive and force individuals against their will into a life of abuse, servitude and inhumane treatment.
Article 4 of the European Convention on Human Rights states that “No one shall be held in slavery or servitude” and that “No one shall be required to perform forced or compulsory labour”. For the purposes of the article, “forced or compulsory labour” does not include:
- Any service of a military character or, in case of conscientious objectors in countries where they are recognised, service exacted instead of compulsory military service;
- Any service exacted in case of an emergency or calamity threatening the life or well-being of the community;
- Any work or service which forms part of normal civic obligations
The Modern Slavery Act 2015 states that with regard to slavery, servitude and forced or compulsory labour, a person commits an offence if:
- The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude; or
- The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour
The prevention, detection, and reporting of slavery and other associated acts are the responsibility of all Institute employees. Employees have an independent obligation to prevent slavery or forced labour in the Institute and to ensure that any interaction with third parties complies with this policy document and relevant laws.
Employees are required to avoid any activity that may lead to, or suggest, a breach of this policy. If this policy is breached by any employee, disciplinary action may be taken through HR16 Disciplinary policy, which could result in dismissal for misconduct or gross misconduct.
It is the responsibility of the Institute to factor full labour costs into sourcing and production in order to avoid the need for slave or bonded labour.
By complying with this policy, HDR UK aims to ensure that employees and the Institute will not at any time knowingly breach any relevant slavery or forced labour legislation, and also that by adhering to the policies and procedures there will be a body of evidence built up to show that if there were any allegation of slavery or forced labour, the Institute in defence can demonstrate that it has adequate procedures in place to prevent such activity.
Reporting Concerns Anti-Slavery procedure
How to raise a concern – internal
- Staff are encouraged to raise concerns about any issue of modern slavery at the earliest stage possible. Concerns should be raised with the Director of Business Operations, staff may express their concerns verbally or put the matter in writing if they prefer
- The Director of Business Operations will arrange a meeting with the staff member as soon as possible to discuss their concern. Staff members may bring a colleague, friend or family member to any meetings under this policy. The individual’s companion must respect the confidentiality of their disclosure and any subsequent investigation
- During the meeting a written summary of the individual’s concern will be taken, and they will be provided with a copy after the meeting. The individual will also be provided with details of how HDR UK propose to deal with the matter
- HDR UK aims 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. However, if an individual wants to raise their concern confidentially, we will make every effort to keep the individual’s identity secret. If it is necessary for anyone investigating a concern to know the individual’s identity, we will discuss this with the staff member
- HDR UK does not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from an employee. It is also more difficult to establish whether any allegations are credible and have been made in good faith. Any individual who is found to be making a malicious or vexatious claim may be subject to disciplinary action under HR16 Disciplinary policy
- Employee concerns can relate to the conduct of the Institute itself, but they may sometimes relate to the actions of a third party. The law allows employees to raise a concern in good faith with a third party, where they reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, the Institute encourages staff to report such concerns internally first. Employees should contact the Director of Business Operations for guidance
- Modern Slavery concerns will be kept confidentially, and appropriate reporting will be provided to our board of Trustees
- If you believe the issue is a safeguarding issue rather than one concerning Modern Slavery please refer to P26 Safeguarding policy
How to raise an issue – external
If you need to report an issue outside of HDR UK, please do so via the national modern slavery helpline which can be found at the following link, https://www.modernslaveryhelpline.org/report