Effective Date: 25-Feb-2025
Last Updated: 25-Feb-2025
Purpose of this Policy
Modern slavery is a criminal offence under Section 54(1), Part 6 of the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or 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.
This document sets out the policy of South Coast Insulation Services Ltd, with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.
As a company, we have 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 businesses or those of our suppliers.
The prevention, detection and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the company or under its control.
Steps for the prevention of Modern Slavery
We are 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 of the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children We require our suppliers to hold their own suppliers to the same high standards.
We procure goods and services from a restricted range of UK suppliers. Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains.
We acknowledge the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although the company considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:
• Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.
• Making sure our procurement strategies and contract terms and conditions include references to modern slavery and human trafficking.
• Continuing to take action to embed a zero-tolerance policy towards modern slavery, ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices.
Responsibility for the Policy
Ultimate responsibility for the prevention of modern slavery rests with the company’s leadership. The Board of Directors of South Coast Insulation Services Ltd has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.
Managers at all levels are responsible for ensuring that 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.
Actions to report Modern Slavery or Human Trafficking
The company encourages anyone to raise concerns about modern slavery, using its Whistleblowing Policy if necessary and will support anyone who acts in good faith.
Internal Employees are encouraged to raise any concerns about suspected modern slavery associated with the company or our suppliers and should do this through their line-manger.
External Members of the public or people not employed by the company are to write, in confidence, to the Managing Director at the registered office or via e-mail to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.
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.
The company will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.
Breaches of this Policy
If an issue is identified with a supplier, we will work with them to prepare a corrective action plan and resolve all violations within an agreed upon time period.
We reserve the right to terminate our relationship with individuals and organisations in our supply chain if they breach this policy.
Communication and Awareness of this Policy
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.
Activity During Year Ending March 2024
Throughout 2023-2024 the company has continued to run the various controls and activities outlined in its policy.
The company did not receive any reports of instances of modern slavery or human trafficking and of the need for proper due diligence and risk assessment processes to be applied by staff and suppliers, in accordance with its policy.
Review
This policy will be reviewed at least annually and revised as and when necessary should there be legislative or organisational changes within the Company.
This policy has been endorsed by the CEO and has the full support of the Management Board.
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