Anti-Modern Slavery Statement
INTRODUCTION
The Statement summaries UK Nationwide Ltd's efforts to comprehend every risk of modern slavery associated to its business and to put measures in place aimed at preventing human trafficking and slavery in both its own operations and supply networks.
The organisation is aware of its obligation to prevent slavery and human trafficking as a member of the hospitality and security sectors.
Additionally, our company is committed to eliminating slavery and human trafficking in its operations and making sure that its supply chains are free of slavery and human trafficking.
ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
This statement covers the activities of UK Nationwide Ltd:
· UK Nationwide is an independent hospitality & security company specialising in facility management. The organisation was established in 2011 and now has over ten years of experience in the hospitality & security sector. In order to meet the demands and expectations of each client, UK Nationwide Ltd develops a partnership with each one its clients, understand their need and strategy which enables the company to provide them with bespoke services in order to meet the clients expectations.
· UK Nationwide Ltd provides specialist hospitality & security guarding services.
· The workforce of the company is employed on a permanent contractual basis. The Immigration, Asylum and Nationality Act 2006, BS 7585:2012 standards, and SIA requirements are followed when conducting right to work, residency, security industry authority, and employment history verification checks. We have made sure that all employees receive their monthly National Minimum Wage and Benefits payments on time on a monthly basis.
The organization currently operates in the following country:
• England
There are no activities that are thought to be a high risk of human trafficking and slavery.
Through a supplier/procurement code of conduct, it will be the responsibility of the company to guarantee that all suppliers adhere to the Modern Slavery Act of 2015.
RESPONSIBILITY
The following people are in charge of the organization's anti-slavery initiatives:
• Policies: Operations Manager and Managing Director.
• Investigations/Due Diligence: The Operations Manager is responsible of conducting inquiries and investigating due diligence in connection to known or suspected instance of human trafficking and slavery that are either known or suspected. Site visits are carried out to make sure that there are no unsafe or unhygienic working environments for the staff members.
• Training: The Operation Manager is responsible of making sure that everyone in the organisation and every link in the supply chain are aware of the hazards of slavery and human trafficking.
RELEVANT POLICIES:
Following are the organisation's policies that outline how it identifies modern slavery hazards and takes action to stop slavery and human trafficking in its operations:
• Employee code of conduct: This organisation’s code outlines the actions and behaviors that are required of workers when they represent the organisation. The organisation strives to maintain the highest stand or employee conduct and ethical behaviour when operating on other sites and managing its supply chain.
• Supplier Code of Conduct: The organisation is dedicated to ensuring that its suppliers uphold the highest ethical standards. Suppliers must demonstrate that they employ labor ethically and within the law, treat workers with respect and dignity, and ensure safe working conditions where appropriate. All potential and current suppliers are expected to submit a supplier questionnaire as part of the supply chain selection process. The suppliers must also demonstrate compliance with the Asylum and Immigration Act of 2006, the Labor Standards, and the standards general principles. This enables the procurement team to identify any possible risk to the quality of service to deliver high-quality services or goods, as well as to stop any slavery or human trafficking. The supplier code of conduct is examined during audits of all suppliers.
• Recruitment Policy: The organisation exclusively hires individuals on a contractual basis. All employees are subject to right to work, residency, Security Industry Authority, and employment checks prior to the start of employment in line with the Immigration, Asylum, and Nationality Act of 2006, the Security Industry Authority, and the BS 7585:2012 code of conduct. The hiring process complies with all applicable UK laws. Since it includes the minimum wage, it is not at risk to human trafficking or slavery.
• Corporate Governance and Social Responsibility Policy: UK Nationwide’s corporate governance and social responsibility policy outlines the duties of the board of directors as well as the organization's commitment to workplace safety, health, and the environment. It also provides assurance to the supplier chain code of conduct. The policy is clarified to the entire workforce and is covered in the induction program.
• Anti-Bribery Policy: The organisation's anti-bribery policy strives to prevent any type of bribery from being committed by any stakeholder(s) associated within the organisation. The policy is explained to every employee and is covered is covered in the induction program.
DUE DILIGENCE
In its pursuit of excellence, the organisation exercises due diligence when contemplating the addition of new suppliers and regularly reviews its existing supplier relationships. The organisation's due diligence and review processes encompass the following aspects:
- Assessing the risks associated with modern slavery and human trafficking for each prospective supplier in accordance with the supply chain selection procedure.
- Conducting supplier audits under the oversight of the UK Nationwide Compliance Director, with a heightened focus on slavery and human trafficking when general risks are identified.
- When necessary, taking corrective measures to enhance the practices of underperforming suppliers. This includes offering guidance to suppliers and mandating the implementation of action plans where applicable. Audits conducted by UK Nationwide Ltd suppliers have consistently affirmed their adherence to the UK Nationwide Ltd supplier code of conduct, eliminating the need for improvement plans.
- If required, implementing sanctions against suppliers that fail to improve their performance in accordance with an action plan or gravely violate our supplier code of conduct, which may include terminating the business relationship. Audits conducted by UK Nationwide Ltd suppliers have consistently confirmed their alignment with the UK Nationwide Ltd supplier code of conduct, precluding the issuance of any sanctions, including contract terminations.
- Affirming the right of employees to freely form or join unions when deemed necessary.
PERFORMANCE INDICATORS
In light of the introduction of the Modern Slavery Act 2015, the organisation commits to reviewing its existing supply chains by the conclusion of the financial year to ensure their compliance with the Modern Slavery Act 2015.
TRAINING
The organisation mandates that all staff members, including managerial personnel, undergo awareness training on modern slavery as an integral module within the organisation's induction, management development, and refresher programs.
The organisation's modern slavery awareness training encompasses the following key areas:
- Examination of our business procurement practices, which exert a significant influence on supply chain conditions and should, therefore, be designed to prevent the acquisition of goods and services at unrealistically low prices, the utilisation of labour engaged at wages below a country's national minimum wage, or the fulfilment of product orders within an impractical timeframe.
- Instruction on evaluating the risk of slavery and human trafficking across various facets of the business, inclusive of available resources and support.
- Guidance on recognizing indicators of slavery and human trafficking.
- Protocols for escalating potential issues related to slavery or human trafficking to the relevant parties within the organisation.
- Guidance on the necessary steps the organisation should take if suppliers or contractors fail to implement anti-slavery policies in high-risk scenarios, including their potential removal from the organisation's supply chain.
This statement has been formally approved by the organisation's Director, who will conduct an annual review and make necessary updates.
