Modern Slavery
Statement
Modern Slavery Statement
What is modern slavery?
Modern slavery is an international crime affecting millions of people around the world – a growing global issue that transcends age, gender and ethnicity. Sadly, vulnerable people from overseas, as well as across the UK, are forced to work illegally against their will across many different sectors, from agriculture, construction, hospitality, retail, manufacturing, and more.
- Our Organisation Structure and Supply Chains
- TES is a private limited company, incorporated in Northern Ireland. Our business largely uses professionally qualified people employed directly by TES. Our people policies ensure fair treatment of our people around the world.
- Our external suppliers are mostly UK and EU based companies in low-risk sectors such as Manufacturing and Engineering.
- Policy Statement
- 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. TES have 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.
- TES 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 sub-contractors, suppliers and other business partners. 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 have their own suppliers to the same high standards.
- This policy applies to all persons working for TES or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, sub-contractors, external consultants, third-party representatives and business partners.
- This policy does not form part of any employee’s employment contract, and we may amend it at any time.
- Responsibility for the Policy
- The board of directors is responsible for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
- The HR 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 effectively counter modern slavery.
- Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy. They are given adequate and regular training on it and the issue of modern slavery in supply chains.
- 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 compliance manager.
- Compliance with the Policy
- You must ensure that you read, understand and comply with this policy.
- 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.
- You must notify your manager or the compliance as soon as possible if you believe or suspect a conflict with this policy has occurred, or may occur in the future.
- 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.
- Suppose you believe or suspect a breach of this policy has occurred or that it may occur. In that case, you must notify your manager or report it as soon as possible in accordance with our whistleblowing policy.
- 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 HR Manager.
- TES aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they are 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 any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered such treatment, you should inform the HR manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
- Due diligence processes, risk assessment and management
- The implementation of our policies and procedures includes due diligence on suppliers that we engage with in accordance with our procurement policy. A heightened risk area is the use of hotel and conference facilities. To mitigate against this risk, we assess the companies we deal with as part of the decision-making process for events and travel.
- When we admit a new company to the TES-approved supply chain, a thorough due diligence process takes place to ensure that the firm has a good reputation and appropriate practices in several areas, including people and culture. Once approved, compliance with TES policies is a condition of continued ‘approved’ status.
- Communication and Awareness of this Policy
- 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.
- 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 after that.
- Breaches of this Policy
- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
- TES may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.