1. About this policy
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the LACE Partners slavery and human trafficking statement.
Considering the obligation to report on measures to ensure that all parts of our business are slavery-free we have put in place a designated Modern Slavery Policy.
This policy applies to all staff including third parties and Company Directors.
2. Policy objectives
Our Modern Slavery Policy demonstrates 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 organisation or knowingly in our supply chain.
LACE Partners are also committed to reporting to the appropriate authorities any organisation or group we suspect of taking part in Modern Slavery or Human Trafficking including breaching the human rights of their workers.
This policy has been written using the following UK Government guidance: Transparency in Supply Chains etc., A practical guide, 2015.
Public Health England describes Modern Slavery as follows “Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men using force, coercion, abuse of vulnerability, deception or other means for exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel to exploit them soon after.”
Modern slavery permeates every corner of our economy. In our industry, we may encounter Modern Slavery through:
- Trafficked or enslaved individuals working for our business partners or customers
- Trafficked or enslaved individuals in the supply of our services chain, which includes workers being provided by employment agencies and other service providers such as cleaning contractors or logistics operators
- Trafficked or enslaved individuals in any part of our goods or raw materials supply chain
4. Poor labour practices
Whilst not meeting the definition of modern slavery, a lack of basic human rights provided to workers such as non-compliance to paying the minimum wage,
providing poor or unsafe working conditions or any form of maltreatment or exploitation is considered by LACE Partners as unacceptable.
We are committed to ensuring that the following poor labour practices form no part of our business activities or those of our business partners:
- Long working hours over and above safe and legal limits
- Health and Safety issues
- Mental Health impacts
- Precarious employment, with most workers either self-employed or on zero-hours contracts
- Bullying and harassment
- Fear of speaking out due to retaliation
5. Roles and responsibilities
All staff are equally responsible for the prevention, detection, and reporting of modern slavery and have a responsibility to:
- Engage with training and be aware of the signs of modern slavery
- Know what to do should they suspect modern slavery
- Follow this policy in its entirety and only engage with ethical and responsible partners including customers and suppliers
6. Responsible recruitment
LACE Partners has a robust recruitment procedure where all potential employees are screened to ensure that:
– They are eligible to work in the UK
– They are of legal age to work
– Have the correct documents to prove right to reside and work in the UK.
Employees are also:
– Paid a fair wage that meets or exceeds the UK legal requirements
– Paid directly (not paid to another individual on the individual’s behalf)
– Given a Contract of Employment
– Provided with working conditions that are safe, comfortable, fair and legal in line with or above the minimum specified by UK health and safety laws
– Are mentored and supported in the workplace
– Trained in recognising, preventing and reporting Modern Slavery.
Self-employed contractors are also screened to ensure that they are eligible to work in the UK, given a service contract, given the same health and safety protections afforded to employees and receive adequate training and support.
7. Responsible service suppliers and partners
LACE Partners is committed to maintaining responsible partnerships within our service suppliers and will only work with reputable employment agencies and businesses that have a robust approach to tackling modern slavery and ensuring legal and safe labour practices.
This approach covers workers provided to LACE Partners and workers contracted to work for our business partners such as facilities providers, hauliers, cleaners and security guards.
Any agencies, employers or partners supplying workers to LACE Partners will be required to provide evidence of legal compliance and supporting policies and procedures.
This includes a tendering process which includes:
- Checking the pre-approved supplier list and taking recommendations from sound ethical business partners; and
- Requesting copies of the supplier Modern Slavery Statements/Policies, Health and Safety Policies and other policies related to safe and health working practices; and
- Reinforcing our commitment to sound labour practices and ensuring that suppliers agree to our terms; and
- Where appropriate, requesting breakdown of costs to ensure worker wages are legal; and
- Requesting information on where and how workers are sourced and details of their employment status (employed full time, zero-hours contract etc).
LACE Partners’ terms for third parties, as a contractual agreement are as follows:
- We expect all third parties working with us to ensure sound and legal labour practices within their organisation as per the Human Rights Act 1998 and United Nations Universal Declaration of Human Rights;
- We expect all third parties working with us to provide support for their workers to ensure their health, safety, and wellbeing;
- We expect all third-party workers to be appropriately and legally categorized, be of working age and paid at least the minimum wage;
- We reserve the right to conduct welfare checks of any worker on site.
Any LACE Partners staff member who has suspicions of modern slavery practices in any contractor, sub-contractor or partner organisation should report them to the Director immediately.
LACE Partners will not work with or engage with workforce supplier or partner who fails to meet our tendering process or agree to our terms and conditions.
8. Responsible goods and raw materials supply chain
LACE Partners has a responsibility to ensure no slavery has been used in the production of the goods we procure, sell on or supply to others. This applies to goods purchased directly by us, our suppliers, and suppliers of their suppliers, all the way down the supply chain.
Unfortunately, Modern Slavery is more prominent in some countries, within certain groups and certain supply chains. LACE Partners, therefore, understands that reviewing the Global Slavery Index and the Modern Slavery Registry regularly is part of our commitment to combatting such practices.
In addition, LACE Partners will not work with suppliers who have been convicted of or are being investigated for:
• Child Labour
• Forced Labour
• Human Rights Violations
• Environmental Violations
When purchasing any goods manufactured for LACE Partners, we will ensure that we:
- Choose reputable suppliers who provide a high-quality product without compromising labour practices or using slavery in the supply chain, through requesting cost breakdowns and ensuring that suppliers abide by our terms (as above); and
- Do not compromise our integrity by encouraging bidding wars which could negatively affect labour practices through underpricing goods and undercutting worker wages; and
- Ensure that the supplier can provide evidence of their policies where applicable and proof of sound business practices through the provision of health and safety and other policies; and
- Give the supplier adequate notice of delivery to ensure that no trade-off is necessary to deliver within the contract.
LACE Partners will cease to work with organisations that fail to provide the relevant documentation and/or agree to our terms.
9. Due diligence – going further
LACE Partners acknowledges that some organisations will go to great lengths to hide modern slavery and poor labour practices. We seek to ensure that we support human rights due diligence in our supply chain.
Not only do we use widely available tools such as the global slavery index, but where necessary, seek to investigate and clarify working conditions with support from expert independent, third parties and civil society stakeholders, or from workers themselves about their working conditions.
10. Monitoring and reviewing
The LACE Partners Directors are responsible for monitoring the effectiveness of this policy and will review the implementation of it regularly, assessing its suitability, adequacy, and effectiveness.
We will review any incidents where a report has been made regarding modern slavery or poor labour practices becoming apparent in our business or a third-party supply chain, and action plans will be agreed upon to improve our policies and working practices. These may include but are not limited to:
- Increased or revised staff training
- Increased staff support
- Terminations of contracts with partner companies or organisations
- Terminations of contracts with suppliers
- Reports to the authorities
- Disciplinary action against employees who do not follow this policy
11. Guidance and training
Spotting the Signs of Modern Slavery
The charity Anti-Slavery have identified the following as possible signs of an individual being in slavery.
Any individual or individuals who:
- Appear to be under the control of someone else and reluctant to interact with others
- Do not have personal identification on them
- Have wages paid to another individual on their behalf
- Have limited English vocabulary
- Have few personal belongings, wear the same clothes every day or wear unsuitable clothes for work
- Is living in squalid, overcrowded accommodation
- May not be able to move around freely
- Are reluctant to talk to strangers or the authorities
- Appear frightened, withdrawn, or show signs of physical or psychological abuse
- Are always dropped off and collected for work in the same way, especially at unusual times, i.e., early for their shift, or late at night
- Are forced to work long hours or multiple jobs
Modern Slavery and Exploitation also includes:
- Sexual abuse, including where children are forced into relationships with much older individuals
- Harvesting of organs from individuals against their will
- Child labour including County Lines (Mobile phone lines used by criminal gangs to organise illegal drugs to be moved and sold from one village, town, or city to another across the UK, with children most often used to move and sell the drugs)
- Child marriage (if the marriage is forced and the child cannot reasonably leave the marriage)
- Trafficked or enslaved individuals may avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family
- The signs above may not always indicate modern slavery, but must not be ignored, and advice from professionals should always be sought
12. Raising a concern
Any staff member who suspects Modern Slavery, Human Trafficking or Exploitation should:
• Not confront the individual, individuals, or business directly; and
• Inform a director immediately; and
• Go to a quiet, secure place and use the information below to report your concerns
If you are in the UK and suspect someone might be in slavery, you have several options:
Call the Modern Slavery Helpline on 08000 121 700 or fill out an online form at https://www.modernslaveryhelpline.org/report
Contact the Gangmasters and Labour Abuse Authority to report concerns about the mistreatment of workers on 0800 432 0804, or by email email@example.com
Contact Crimestoppers on 0800 555 111.
Contact the Police on 999 if a crime is or has been committed, life is in danger or children are at risk
13. Further resources and training
The following organisation has been recommended by the UK Government to support businesses tackle modern slavery: https://www.stronger2gether.org
14. Potential sanctions
All deliberate breaches of this policy will be investigated under the Disciplinary Policy.
Users who do so will be subject to disciplinary action, up to and including termination of employment or service contract.
Breaches will be escalated to the Board of Directors as part of the organisation’s risk management process and reviewed.
Employees, contractors and other users may also be held personally liable for violating this policy.
Where appropriate, LACE Partners will involve the police or other law enforcement agencies concerning breaches of this policy.
Date: 1st December 2023