Modern Slavery and Anti-Human Trafficking Policy

Details of policy

Policy Statement

This policy details the stance taken by Corrigenda with regard to Modern Slavery and Human Trafficking in compliance with the Modern Slavery Act 2015.

Corrigenda has a zero-tolerance approach to modern slavery and the company is committed to acting ethically and with integrity in all our business dealings and relationships, and to implement and enforce effective systems and controls to ensure modern slavery is not happening anywhere in our own business or, as far as we may determine, our supply chain.

How we will carry out, monitor and enforce this Policy

Modern slavery is a crime and a violation of fundamental human rights. It is a hidden harm which can have life-long deleterious effects to those affected. It can take various forms including, but not limited to, slavery, servitude, forced and compulsory labour, the use of children as labour, withholding documents, demanding additional fees or payments, denial of benefits, denial of basic human rights such as healthcare, demanding services of a sexual nature in return for favourable treatment and human trafficking, all of which have in common the deprivation of a person’s rights, freedoms and liberty by another in order to exploit them for personal or commercial gain.

We are committed to ensuring there is transparency in our own business and clarity in our approach to tackling modern slavery. We expect the same high standards from all of our contractors, suppliers and others. 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) and we expect that our suppliers will, in turn, hold their own suppliers to the same high standards. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners, consistent with our disclosure obligations under the Modern Slavery Act 2015. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Reporting suspected cases of Modern Slavery or Human Trafficking.

Workers are informed of, and have access to, a means for reporting an actual or suspected instance or risk of slavery or human trafficking. Individuals working on Corrigenda’s behalf are able to access Company reporting and whistleblowing procedures to allow circumstances to be noted and investigated by senior personnel best placed to take affirmative action, and to determine procedures and activities which are to be taken to protect those at risk from harm.  Information on how to do this is contained within the Corrigenda Staff Handbook, issued to every new member of staff on starting.

Staff 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 to any manager within Corrigenda or directly to the Health and Safety Manager.

Payment of or demands for additional fees as a condition of employment or introduction.

Corrigenda, in line with its policy and Standard Operating Procedure on Recruitment, explicitly prohibits the imposition of any employment-dependent financial obligations such as withholding wages or imposing recruitment fees on workers. Corrigenda expressly forbids any recruiters to act on behalf of the Company where such practices take place, are implied, or conditional on introduction to Corrigenda.

Supplier Code of Conduct.

As the contracting organisation, and in furtherance of our own due diligence, we expect our suppliers to both ensure that their practices are supportive of our determined approach to tackling modern slavery. We expect to purchase goods and services that have been ethically produced and delivered with as minimum an impact on the environment as possible, and with due regard for social issues such as employment conditions and welfare.  Further, we expect that our suppliers will be able to demonstrate their stance on Modern Slavery and Human Trafficking by the production of a policy (where required by legislation) and being able to evidence practices which show their own firm commitment to keeping people safe from exploitation and harm.   Further, Corrigenda has the expectation that the contractor shall take all reasonable steps to ensure that no slavery or human trafficking is taking (or has taken) place within their own business and in any part of its supply chains as far as they are able, irrespective of the legislative requirement for a formal statement.