Anti-Slavery and Human Trafficking Policy

Policy Statement

 

This policy applies to all persons working for GOOD ADVICE UK or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, suppliers, vendors, external consultants, third-party representatives and business partners.

 

GOOD ADVICE UK strictly prohibits the use of modern slavery and human trafficking in our operations and is committed to acting ethically and with integrity in all our business dealings and relationships and implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation. We expect the same high standards from all of our contractors, suppliers and other business partners.

 

This policy does not form part of any employee's contract of employment and GOOD ADVICE UK may amend it at any time.

 

Modern Slavery and Human Trafficking

 

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

 

Commitments

 

GOOD ADVICE UK is committed to ensuring there is transparency in our own organisation and in our approach to tackling modern slavery, consistent with our disclosure obligations under the Modern Slavery Act 2015.

 

GOOD ADVICE UK expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation.
  • The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us or on our behalf. Employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of vendors for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

 

 

 

Responsibility for Policy

 

The Director(s) have overall responsibility for ensuring this policy with management; and managers have day-to-day responsibility to ensure compliance with our legal and ethical obligation.

 

The Director(s) and managers have 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.

 

Managers 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.

 

Compliance with this 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 organisation 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 Director as soon as possible if you believe or suspect that 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 organisation 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 Director or you may report it in accordance with our Whistleblowing Policy as soon as possible.

 

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitutes any of the various forms of modern slavery, you must raise it with your manager the Director.

 

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.

 

GOOD ADVICE UK 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 any part of our own organisation.

 

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 your manager or the Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure.

 

Communication and Awareness of this Policy

 

Training on this policy, and on the risk our organisation faces from modern slavery, 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 thereafter.

 

Breaches of this Policy

 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

 

GOOD ADVICE UK may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

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