1. Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Environmental Innovations has a zero-tolerance approach to modern slavery.
2. Scope
This policy applies to all colleagues working for Environmental Innovations, or on our behalf, in any capacity including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives, and business partners. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
Under Section 54 of the Modern Slavery Act 2015 some organisations are required to prepare a slavery and human trafficking statement for each financial year, setting out the steps that the organisation has taken during the year to ensure that slavery and human trafficking is not taking place in its supply chains or its own business (or setting out that it has taken no such steps).
However, the duty applies to commercial organisations with a total turnover of at least £36 million per year. “Commercial organisations” that are covered by the duty are body corporates and partnerships that carry on a business, or part of a business, in the UK, supplying goods or services. Therefore, for clarification purpose Environmental Innovations is not obliged to prepare a slavery and human trafficking statement for each financial year of the organisation, however we have decided to adopt the following policy as part of our ethical approach to business.
3. Policy Statement
Environmental Innovations has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners, and we expect that our suppliers will hold their own suppliers to the same high standards. We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
4. Related policies.
This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the following workplace policies and procedures which can be found in our HR and H&S Platform.
You are encouraged to familiarise yourself with the policies detailed below.
• Whistleblowing policy
• Corporate Social Responsibility policy
• Equality and Diversity policy
If you have any queries about this policy, please contact our operations manager.
5. Our Supply Chain
Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business.
Our supply chains are limited, and we provide services from a restricted range of UK (and, in rare occasions, overseas suppliers), all of which go through a rigorous pre-suitability assessment. We seek to align ourselves with suppliers who share our core values and culture.
6. Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our business, we have adopted the following due diligence procedures:
Recruitment, Pre-Employment, and Employment
• Mandatory awareness training for all staff involved in human resources and recruitment.
• We have a robust recruitment process which is supported by our recruitment, procedure whose provisions reinforce our commitment to the prevention of slavery and human trafficking.
• When recruitment companies are used to assist in sourcing new colleagues, they are trusted organisations which demonstrate care and diligence in accordance with good practice and they must have a policy recognising, respecting, and protecting the human rights of their employees and candidates.
• All Environmental Innovations activities are carried out in accordance with local and national laws, and in the absence of any specific legal requirements, good practice is adhered to.
• All prospective colleagues continue to undergo an array of pre-employment checks including verifying their identity, right to work in the UK and their professional qualifications where applicable. We have controls in place to highlight scenarios that could be considered potential warning signs of modern slavery e.g., multiple colleagues living at the same address, colleagues with the same bank information.
• Environmental Innovations is committed to supporting staff’s mental and physical wellbeing.
Supply Chain
• A rigorous pre-suitability assessment for all suppliers we engage with.
• Ensuring that consideration of the modern slavery and human trafficking risks and preventions are added to Environmental Innovation’s internal audit and review programme – and any appropriate actions are reflected in our policies and procedures.
• Continuing to embed a zero-tolerance policy towards modern slavery and human trafficking.
• Frequent audits of, and reviews with, our higher-risk suppliers.
• Encourage anyone to raise any concerns about modern slavery, using our whistleblowing policy if necessary, and will support anyone who acts in good faith.
Risk Assessment
Environmental Innovations operates a robust risk management framework; our Risk Assessment Logbook has been designed and developed to capture, monitor, and manage all risks (and potential risks) from identification through to resolution. Our Risk Assessment Logbook is regularly reviewed during weekly team meetings, monthly management meetings, and management system reviews.
Our due diligence procedures aim to
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains.
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
8. Responsibilities
Environmental Innovation’s Directors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligation.
The operations manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
9. Performance Indicators
As part of our commitment to ensuring the effectiveness of our management system, we continue to monitor the effectiveness of the mechanisms we have in place by:
• completion of the annual review of our policies.
• the completion of mandatory training modules.
• completion of pre-employment checks.
• completion of the supplier audit schedule.
5. Compliance with this policy.
You must ensure that you read, understand, and comply with this policy.
1. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
2. You must notify your manager or the operations manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
3. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains (including any supplier tier) at the earliest possible stage. If you believe or suspect a breach of this policy has occurred, or that it may occur, you must notify your manager or the operations manager or you may report it in accordance with our Whistleblowing Policy as soon as possible.
4. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the operations manager.
We aim 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. Environmental Innovations is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the operations manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure which can be found in our HR and H&S Platform or from the operations manager.
This policy is kept under continual review.
This policy has been approved and authorised by:
Name: Brian Back
Position: Managing Director
Date: 6th January 2025