Southwark Works/ JCCS Ltd Anti Slavery Policy
1.This policy applies to all persons working for JCCS Ltd in the Southwark Works network or on our behalf in any capacity, including employees at all levels, directors, seconded workers, volunteers, contractors and suppliers. Southwark Works strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of the organisations or employers we work with.
Modern Slavery and Human Trafficking is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. Southwark Works expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
- We are committed to engaging with our partners and suppliers to address the risk of modern slavery in our operations and supply chain.
- We take a risk based approach to our contracting processes and keep them under review.
- Consistent with our risk based approach we may require employers/recruitment agencies and other third parties working with our organisation to confirm their compliance with this policy
- If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action.
- This policy will be reviewed regularly (at least annually).
RESPONSIBILITY FOR THE POLICY
2.1 The Programme Manager has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Programme Manager and Senior Management Team (SMT) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Programme Manager – firstname.lastname@example.org
COMPLIANCE WITH THE POLICY
3.1 If you are working for Southwark Works (JCCS Ltd) or on our behalf, you must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify the Programme Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business, network or supply chains at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must report it to senior management as soon as possible.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitutes any of the various forms of modern slavery, raise it with Senior Management as soon as possible.
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our networks and supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Programme Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Complaints Procedure, which can be found in the Staff Handbook.
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process and training is provided for employees via the Southwark My Learning Source.
4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, employers, contractors and network or business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.