The Modern Slavery Act 2015 came into effect on 29th October 2015. This law requires organisations operating within the UK to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chain and within their organisation.

Sefton Women’s and Children’s Aid’s (SWACA) efforts to eradicate slavery and human trafficking in its supply chain and own organisation include the following:

Supply chain

Written policies and procedures

SWACA strictly prohibits the user of slavery or human trafficking in its direct supply chain.

Our supply chain vetting process will require that the SWACA’s supply chain validates their compliance with the Modern Slavery Act as part of the application process, with regard to issues of forced labour, slavery and human trafficking.

Contractual obligations

No supplier is engaged by SWACA until they have completed a ‘Supply Chain Assessment Questionnaire’, which is then subsequently vetted. This ensures that they will adhere to the guidelines and expectations that SWACA would expect. SWACA contractual arrangements make reference to the approval process and the evidence submitted by the supplier, and thus mandate the necessary level of compliance with Legislation; Codes of Practice; International, National and Client Standards.

Supply chain monitoring

SWACA reserves the right at any time to monitor its suppliers for compliance against agreed contractual requirements, including and not limited to the Modern Slavery Act.

Compliance with the Modern Slavery Act by SWACA supply chain will be undertaken using the following means:

  • Three year re-vetting of its suppliers.
  • Monitoring of publicised breeches of the legislation.

Violations

SWACA has a zero-tolerance policy towards violations of the laws banning forced labour, slavery and human trafficking.

SWACA contractual agreements permit the termination of suppliers for a single violation.

Our own business

Written policies and procedures

SWACA’s employment handbook details the rules and procedures by which we should treat fellow employees. This includes…

  • Transparent and fair behaviour, such as protecting human rights.
  • Compliance with legislation, including fundamental rights at work – in particular freedom of association and elimination of discrimination throughout employment.

Employee training

SWACA conducts briefings for all employees to emphasise the importance of acting with integrity and in line with our own internal values. Guidance regarding the Modern Slavery Act is incorporated into company training sessions and documentation.

Human rights

SWACA pledges to monitor its position with regard to Human Rights Compliance to ensure that all areas of its business are compliant with current legislation, International Human Rights Standards and our own internal values.

We strive constantly to ensure that all employees are treated in a fair and transparent manner. This includes adherence to the Working Time Directive and the Minimum Wage.

Violations

SWACA’s disciplinary policy details the processes to be followed if any employees are found to be involved in any breach of the law with regard to forced labour, slavery and human trafficking.

SWACA will continue to update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.

Queries

Any questions relating to this policy or the Company’s approach to this issue should be directed to info@swaca.com.