Modern slavery is a crime resulting in despicable abuse of human rights. The Modern Slavery Act (‘MSA’) 2015 came into force in March 2015 and consolidates slavery and trafficking offenses. It covers four activities:
- Forced or compulsory labour
- Human trafficking
It ensures that offences are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002. The National Crime Agency, the police and other law enforcement agencies have the powers to bring to justice those engaged in human trafficking and slavery. Modern slavery is a complex and multi-faceted crime and tackling it requires all partners and employees of CRX Compression Ltd (‘the Company’) to play a part. Protecting our workforce and reputation is vital. The MSA 2015 highlights the important need for businesses, and therefore the Company, to play a part in tackling slavery.
The Transparency in Supply Chains Clause which came into force in October 2015 requires organisations with a turnover of £36m or more to report on processes and due diligence taken to ensure that their supply chains are slavery free, and to produce and publish a slavery and human trafficking statement each financial year. There is no mandatory requirement for the Company to produce an Anti-Slavery Policy but we do so because the Company believes it is appropriate for us to be doing so.
The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to, the following business partners:
- Supply chains
- Outsourced activities
- Cleaning and catering suppliers
- Corporate hospitality
- Recruitment through agencies
- General recruitment
The Company will manage these risks through our procedures set out in this policy.
The Company, all of its employees, Board members and associates have a responsibility to ensure all colleagues and business partners are safeguarded, treated fairly and with dignity. This policy must be observed and any serious concerns which are raised will be dealt with as appropriate and may trigger the Company's disciplinary procedures.
The Company will:
- maintain clear policies and procedures preventing exploitation and human trafficking, protecting our colleagues, business partners and our reputation;
- be clear about our recruitment policy (see ‘Recruitment’);
- check our supply chains (see ‘Supply Chains’);
- make appropriate checks on all employees, recruitment agencies, suppliers, etc.;
- have in place an open and transparent grievance process for all staff.
Directors and Line Managers will:
- listen and be approachable to colleagues;
- respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;
- remain alert to indicators of slavery;
- raise awareness by discussing issues and providing training where appropriate;
- use their experience and professional judgement to gauge situations.
- follow the reporting procedure (see Reporting) if there is any suspicion of a colleague or someone in our supply chain being controlled or forced by someone else to work or provide services;
- follow the reporting procedure if a colleague tells them something that may indicate they are or someone else is being exploited or ill-treated.
The Company will make a clear annual statement which will show a summary of any steps we may have taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of the business or our supply chains.
We are expected to build on our statement each year and therefore show that improvements can be made.
The statement will also show:
- the organisation structure, our business and supply chains;
- our policy in relation to slavery and human trafficking;
- the due diligence processes in relation to slavery and human trafficking;
- the parts of the business and supply chains where there is a risk of slavery and human trafficking, and what steps are being taken to assess and manage that risk;
- training available to partners and colleagues about slavery and human trafficking.
The statement will be approved by the Board and signed by a designated director.
- Risk assessment will include:
- Identifying suppliers by total spend/goods or services/location;
- Supply chains (a supplier is any individual or company which provides goods or services).
- The Company will thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
- We will inform companies that we do business with that we are not prepared to accept any form of exploitation.
- Our supplier contracts may contain an anti-slavery clause which prohibits suppliers and their employees from engaging in slavery or human trafficking.
- Each step of the supply process will be accounted for. We will know who is providing goods and services to us, and we will have mechanisms and processes in place to check, including risk assessing and auditing suppliers.
RECRUITMENT USING AGENCIES
The Company will seek to ensure that all employees and other associates follow the Company's policy and, where we may choose to engage via recruitment agencies, we commit to ensuring that they are reputable agencies.
Where possible, recruitment agencies will be checked to reduce the potential for slavery and human trafficking, and placed on a list of approved agencies. This will be achieved by:
- Conducting background checks;
- Investigating reputation;
- Ensuring supplied staff have the appropriate paperwork;
- Ensuring assurances are provided by the agency that the appropriate checks have been made on the supplied person(s);
- The list of approved recruitment agencies will be reviewed at least every three years.
- All employees will have a written contract of employment and will not be asked to pay any direct or indirect fees to obtain work.
- The Company will ensure that employees are legally able to work in the United Kingdom.
- Names and addresses of employees will be checked to identify a high number sharing occupancy (often a factor for those being exploited).
- Information will be provided to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
- The Directors will follow the Company’s reporting procedure should they suspect that someone is being exploited.
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim. The person:
- may not be in possession of their own passport, identification or travel documents;
- will allow others to speak for them when spoken to directly;
- will be withdrawn or appear frightened;
- does not seem to be able to contact friends or family freely;
- has limited social interaction or contact with people outside their immediate environment.
A person may display a number of the indicators as set out above but they may not necessarily be a victim of slavery or trafficking.
If you have any concerns, you should raise them with the Company’s Director, Dean Conway, on 07768 550605, or via email at email@example.com, who will decide upon a course of action and provide any further advice. If you believe the victim may be in immediate danger, please dial 999. Please be aware, however, that 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.
It is therefore important that in the absence of an immediate danger, you should discuss your concerns first with the Director before taking any further action.
The Company seeks to provide general awareness training by means of presentations and/or webinars.
The Company will monitor its procedures and review the Anti-Slavery policy regularly and at least annually on publication of the annual statement. We will provide information and, if necessary, training on any changes which are made.
CRX Compression Limited (‘The Company’) has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all of our contractors, suppliers and other business partners. We expect them to adopt the same zero tolerance approach to the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
We are a private limited company, incorporated in November 2019, and we provide retail sale via mail order houses and the internet to private sector business and public sector organizations. The Company employs two people, with two additional directors and operates in the United Kingdom, with a manufacturer operating in Portugal in the European Union.
Our supply chains
Our supply chains include a number of suppliers, with a manufacturing supplier in Portugal, and support our business in the provision of materials, equipment and professional services. We have no reason for concern in relation to any current member of the supply chain and their compliance with the Modern Slavery Act 2015.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-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 our supply chains.
We take responsibility for conducting and growing our business in a sustainable and responsible manner. We understand the impact our activities can have on the environment and society and endeavour to ensure we eliminate or mitigate the risk of negative impacts. We have committed to incorporating sustainability into our business strategy and adopting sustainable decision-making as an integral part of the way we do business. To that end, we have adopted certain policy statements in relation to sustainability, sustainable procurement and corporate social responsibility, all of which are available internally.
Our Anti-Slavery Policy sets out our approach to modern slavery and applies to everyone working directly or indirectly for or with us. We recognize that appropriate training on modern slavery and the use of forced, compulsory or trafficked labour will increase awareness among our people as well as mitigating the risk within the business and the supply chain.
Training and Education
During the year, our Code of Conduct is being rolled out in the Company and forms part of our induction process for all new employees.
This explains what modern slavery is and informs our people that it is their responsibility to help prevent, detect and report incidences of modern slavery. It advises them to raise concerns about incidences of modern slavery through management.
It also includes specific advice on identifying the warning signs to look out for where there may be incidences of modern slavery and advising employees how to report any concerns.
The Company’s approach to the prevention of modern slavery has stakeholder buy-in from the highest levels of management within our organisation. The policy has been considered and formally ratified by the board. The Director is responsible for compliance.
As part of our supply chain accreditation process, we assess our supply chain against the Modern Slavery Act 2015 and we include our Anti- Slavery Policy in our contracting processes to ensure our supply chain is aligned against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.
We have a clear, unambiguous approach to any supplier or business partner who falls foul of this legislation and a contingency plan is in place in respect of key suppliers. We aim to protect anyone who brings concerns about modern slavery to our attention.
Processes for preventing slavery and human trafficking
As part of our initiative to identify and mitigate risk, we regularly assess our supply chain to check compliance with modern slavery requirements, as part of which we will set out our expectations in relation to modern slavery and request that they make the same commitment.
We have an accepted approach for suppliers who breach the Modern Slavery Act 2015 and this is to communicated to our supply chain and business partners via the policy and statement.
We have a dedicated person, the Director responsible for compliance, for dealing with concerns about compliance with the Act and protections in place for anyone who brings matters of concern to our attention.
We are satisfied that we have in place systems to:
- Identify and assess potential risk areas in our supply chains;
- Mitigate the risk of slavery and human trafficking occurring in our supply chains;
- Monitor potential risk areas in our supply chains; and
- Protect whistle blowers.
Our effectiveness in combating slavery and human trafficking
We use standard industry accreditation schemes to certify our supply chains’ compliance with modern slavery requirements. This is carried out on an annual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company's slavery and human trafficking statement for the calendar year ended 31st December 2022, and outlines the steps we have taken as an organization to assess our operations and supply chain and mitigate any risk of slavery and human trafficking. The statement is reviewed annually.