Modern Slavery and Trafficking statement
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT – October 2021
1 INTRODUCTION
1.1 This Modern Slavery and Human Trafficking Statement relates to actions and activities during the [current] financial year 21-22.
1.2 The statement sets down Rob Greenwood Painting and Decorating commitment to preventing slavery and human trafficking (including all forms of exploitation) in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
2 ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
2.1 This statement covers the business activities of Rob Greenwood Painting and Decorating which are as follows:
2.2 Rob Greenwood Painting and Decorating currently operates in the following countries:
2.2.1 England – Decorating
Scotland – Decorating
Wales - Decorating
3 HIGH RISK ACTIVITIES
3.1 [The following is the process by which Rob Greenwood Painting and Decorating assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking:
3.1.1 Employing Sub - Contractors
3.2 The following activities are considered to be at high risk of modern slavery or human trafficking:
3.2.1 Employing Sub – Contractors, due to other company’s outsourcing
3.3 Responsibility for Rob Greenwood Painting and Decorating’s Anti-Slavery initiatives is as follows:
3.3.1 Policies: Rob Greenwood is responsible for creating and reviewing policies. The process by which policies are developed [are by periodic reviews of good practice, adapting to the needs of the business and reviewing contracts and insurance annually to identify policy areas].
3.3.2 Risk assessments: Rob Greenwood is responsible for risk assessments in respect of human rights and modern by a process of filling out risk assessments where necessary
3.3.3 Due diligence: Rob Greenwood is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
4 TRAINING
4.1 To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, Rob Greenwood Painting and Decorating requires [all staff][senior employees] to complete an online training course within six months of appointment [and annually thereafter] [by a training provider approved by Rob Greenwood Painting and Decorating]
5 POLICIES
5.1 Rob Greenwood Painting and Decorating is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
5.2 The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
5.2.1 Whistle-blowing and Protected Disclosure Policy https://www.rgdecorating.co.uk/legal/Whistleblowing Rob Greenwood Painting and Decorating encourages all its workers, customers and other business partners to report any concerns related to its direct business activities or its supply chains.
5.2.2 Anti-Bribery and Anti-Corruption Policy https://www.rgdecorating.co.uk/legal/Anti.bribery Rob Greenwood Painting and Decorating is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations and take measures to prevent corrupt and unethical practices.
5.2.3 Environment and Sustainability Statement https://www.rgdecorating.co.uk/legal/Ess summaries how we manage our environment impact and the actions we take to conduct our business sustainably.
5.2.4 [Employee][Company] Code of Conduct https://www.rgdecorating.co.uk/legal/Coc sets down the actions and behaviour expected of employees when representing Rob Greenwood Painting and Decorating
5.2.5 [Corporate Social Responsibility (CSR) Policy] https://www.rgdecorating.co.uk/legal/Ess Rob Greenwood Painting and Decorating’s CSR policy summarises [how we manage our environmental impacts and] how we work responsibly with suppliers and local communities.
6 DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
6.1 Rob Greenwood Painting and Decorating undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Rob Greenwood Painting and Decorating’s due diligence process includes but not limited to:
6.1.1 using only suppliers of outstanding repute; and
6.1.2 building long-standing relationships with suppliers and making clear our expectations of business partners; and
6.1.3 evaluating the modern slavery and human trafficking risks of each new supplier; and
6.1.4 invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
7 PERFORMANCE INDICATORS
7.1 Rob Greenwood Painting and Decorating uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including but not limited to:
7.1.1 verify that all suppliers have publicly published their statement on modern slavery and human trafficking; and
7.1.2 verify that all suppliers hold a recognised accreditation that is wholly relevant for their supply business and the same remains valid during the course of supply; and
7.1.3 verify that all suppliers have appropriate labour monitoring processes and payroll systems in place; and
7.1.4 verify all suppliers staff have completed training on modern slavery and human trafficking, including exploitation.
7.1.5 incorporate the above into the supply contract with appropriate enforcement mechanisms in place.
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