Modern Slavery Policy


1. Introduction

We are committed to combatting the risks of slavery and human trafficking.  Slavery occurs where a person holds another person in slavery or servitude or forces that person to perform forced or compulsory labour.  Human trafficking occurs where a person arranges or facilitates the travel of another person with a view to that other person being exploited.  To combat these risks, and to fulfil our local responsibility under the UK Modern Slavery Act 2015, we are committed to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chain.

2. Zero Tolerance

Allcooper adopts a zero-tolerance approach to slavery and human trafficking.  We are committed to taking all reasonably practicable steps to ensure that slavery and human trafficking is not present either in our business or in our supply chains. In order to achieve this, we seek to ensure that there is transparency in our approach by identifying and tackling slavery and human trafficking risks.

We expect the same standards from all those we work with, including business partners, contractors and suppliers. Allcooper is committed to working closely with our suppliers to ensure that slavery and human trafficking risks are identified and managed proactively.

3. Application

This policy applies to all staff and external contractors working for or on our behalf in any capacity.  This includes employees, directors, agency staff and consultants. It also includes our suppliers, contractors, business partners and third party representatives.  We may issue amendments to this policy at any time.

4. Overall responsibility

Allcooper's Board of Directors has overall responsibility for formulating our slavery and human trafficking compliance strategy, this policy and for ensuring that this policy is complied with.

All levels of management within Allcooper are responsible for ensuring that those who report to them understand and comply with this policy. This responsibility extends to ensuring that steps are taken to report any slavery and human trafficking issues which are identified.  If you have any queries in relation to this policy, or suggestions for how this policy could be improved, please direct them to the HR Dept.

5. Compliance

You must ensure that you read, understand and comply with this policy. This includes avoiding any action which might result in a breach of this policy.  Everyone to whom this policy applies is responsible for preventing, detecting and reporting instances of slavery and human trafficking in any part of our business or in our supply chains. If you believe that there has been a breach of this policy or that a breach may occur in the future, you must notify the HR Dept. as soon as possible. This extends to any suspicion you may have that slavery or human trafficking exists in any part of our business or supply chains.

6. Examples

The following are recognised examples of unusual behaviour displayed by workers which may be indicative of someone experiencing slavery or human trafficking:

a) Workers not possessing legal documents;

b) Multiple workers being paid wages into the same bank account;

c) Unusual transport arrangements;

d) Appearance (for example, signs of malnourishment, physical injuries, few personal possessions);

e) Signs of intimidation or workers not speaking for themselves;

f) Inconsistencies in background stories; and not seeking medical care; not approaching authorities; or being in debt (or other dependence on someone else).

7. Questions

If you have any questions regarding how this policy applies, you should raise these with the HR Dept. This includes any questions relating to particular actions, working conditions or any other issue relating to the treatment of workers either in our business or any tier of our supply chains. You can also raise any queries you have with your manager.

We will support anyone who raises genuine concerns in good faith under this policy, even in circumstances where it transpires that those concerns are mistaken. We will take steps to ensure that those who report such concerns do not suffer adverse treatment. Adverse treatment includes bullying, harassment, threats, disciplinary action or dismissal connected with raising a genuine concern in good faith. If you are an employee who believes that you have suffered any adverse treatment after raising such a concern, you should raise the matter formally under our Grievance Procedure.

8. Responsible Procurement

To identify and mitigate the risk of slavery and human trafficking being present in our product supply chains, we shall employ a number of sourcing strategies, which may include:

a) Informing our suppliers of the standards that we expect through our Supplier CSR Commitment;

b) Identifying potentially at-risk suppliers.

c) Communicating concerns to at-risk suppliers.

d) Assessing suppliers which includes scoring based on factors such as health & safety, child labour, slavery and payment of the minimum wage.

e) Analysing the results of our assessments; and conducting on-site audits where applicable.

f) As far as reasonably practicable, investigations should be undertaken into the supplier’s supply chain, particularly where that supplier operates in a high risk country.

9. Recruitment

Our suppliers include recruitment agencies who supply us with staff.  Relevant agreements for these agencies shall require them to take particular care to ensure that:

a) All staff that they supply have a written contract of employment;

b) All staff that they supply have not had to pay any direct or indirect fees to obtain work;

c) All staff that they supply are legally able to work in the UK.

d) Checks are made to assess whether multiple workers are living at the same address or being paid wages into the same bank account.

10. Communication and Awareness

Training on this policy and the risks of slavery and human trafficking in our business and in our supply chains forms part of the induction process for all relevant individuals who work for us.  We will also provide upfront and ongoing training to all relevant staff on this policy, including tailored training to those with responsibility for managing high risk supplier contracts.

It is the responsibility of Allcooper colleagues working with third parties (for example, those who manage supplier contracts or recruitment agencies) to communicate to them our zero-tolerance approach to slavery and human trafficking.

Dated: 01 August 2019

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