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Modern Slavery and Human Trafficking Statement

 

Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.

The statement sets down Comply Direct’s commitment to preventing slavery and human trafficking 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.

Organisational Structure

Comply Direct Ltd is a government approved producer compliance scheme and environmental consultancy.  The company has one site based in North Yorkshire and has a turnover of £45 million.

Our Business and Supply Chains

Due to the nature of our business, we deem ourselves to have a low risk of modern slavery in our business and supply chains.

The vast majority of Comply Direct’s suppliers are based in Europe and are bound by the following employment legislation (or the equivalent in their country of operation);

  • Employment Rights Act 1996
  • Working Time Regulations 1988
  • Equality Act 2010
  • Health and Safety at Work Act 1974

Policies

Comply Direct 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 and the following policies serve to support this intention;

  • Ethical Code of Conduct
  • Whistleblowing policy
  • Corporate Social Responsibility policy
  • Supply Chain Labour Standards policy
  • Anti-bribery policy

The Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

Due Diligence Processes for Slavery and Human Trafficking

Comply Direct undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Comply Direct’s due diligence process includes;

  • Building long-standing relationships with suppliers and making clear our expectations of business partners
  • Having a robust supplier approval and monitoring procedure
  • 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

Training

To ensure a high level of understanding of the risks and associated responsibilities in relation to modern slavery and human trafficking in our supply chains and our business, we provide briefings to all employees at induction and annual review points.

Performance Indicators

Comply Direct uses the output of the supplier approval and monitoring procedure (which includes auditing of suppliers) to measure our effectiveness in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains.                      

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.

Reviewed and Authorised By: Jessica Aldersley

Position: HR & Operations Director

Date of Review: 22.10.20

If you have any queries regarding this statement, please contact Jessica Aldersley HERE