Modern Slavery and Human Trafficking Policy
1. Policy statement
1.1 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.
1.2 Fairhome Group plc (the “Parent”) and its group of companies (the “Fairhome Group”) 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 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.
1.3 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 of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.4 This policy applies to all persons working for us 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.
1.5 The Fairhome Group is committed to:
1.5.1 acting ethically and with integrity in all our business dealings and relationships;
1.5.2 implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains; and
1.5.3 ensuring there is transparency in our approach to tackling modern slavery in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.
1.6 We expect the same high standards in respect of tackling modern slavery and human trafficking from all of our suppliers and we expect that our suppliers will hold their own suppliers to the same high standards.
2. Identifying modern slavery
2.1 Modern slavery may be found in:
2.1.1. our business, for example our cleaning and catering workforce;
2.1.2 our supply chains; and
2.1.3 outsourced activities, particularly to jurisdictions that may not have adequate modern slavery safeguards.
2.2 There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:
2.2.1 the person is not in possession of their own passport, identification or travel documents;
2.2.2 the person is acting as though they are being instructed or coached by someone else;
2.2.3 the person allows others to speak for them when spoken to directly;
2.2.4 the person is dropped off and collected from work;
2.2.5 the person is withdrawn or appears frightened;
2.2.6 the person does not seem to be able to contact friends or family freely;
2.2.7 the person has limited social interaction or contact with people outside of their immediate environment.
The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.
3. Responsibility for the policy
3.1 The board of directors of the Parent and the Fairhome Group’s legal team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
3.2 The Head of HR 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.
3.3 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.
3.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Head of HR.
4. Compliance with the policy
4.1 You must ensure that you read, understand and comply with this policy.
4.2 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.
4.3 You must notify your line manager the Head of HR as soon as possible if you believe or suspect that a conflict with or a breach of this policy has occurred, or may occur in the future.
4.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
4.5 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 Head of HR.
4.6 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. We are 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 any 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 compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found at Fairnet.
5. Communication, awareness and publication of this policy
5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
5.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
5.4 This policy is available to the employees of the Fairhome Group on Fairnet and available to suppliers on request.
6. Breaches of this policy
6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.