Modern Slavery & Human Trafficking Policy

Company Name: Bateman Collins Group (BCG)

Incorporating Bateman Collins International Limited and Map Room Limited

Data Protection Lead

Zoe Evans

Model Policy No

PN/0108

Topic:

Modern Slavery & Human Trafficking Policy

Last updated:

08.09.20

1. Introduction

The Company is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. The Company is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

2. Child Labour

The Company does not use child labour. The Company’s Clients, Contractors, Associates and Suppliers do not employ child labour.

3. Working Hours

Company Employees are not expected to work on average more than 48 hours a week.

4. Raising Awareness

The Company provides appropriate training and awareness information for all of its staff. In particular: .

  • Our staff undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues during their induction programme;
  • All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management;
  • Refresher courses are conducted annually as part of the Company’s Annual Training & Development session and modern slavery and human trafficking awareness is included on the Company annual training matrix.

5. Reporting Concerns

Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to the Company’s Compliance Manager, Zoe Evans.

Reports surrounding these issues are taken extremely seriously by our Board of Directors who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

  • Working with the appropriate organisations to improve standards,
  • Removing that organisations from our preferred supplier list,
  • Passing details to appropriate law enforcement bodies.

6. Our Supply Chain

Due to the nature of our business, the Company has a lower risk of modern slavery occurring compared to other sectors, however we’re continuing to improve our procedures to ensure that modern slavery and human trafficking does not occur in our supply chain.

  • We carry out a Modern Slavery assessment as part of our supplier on-boarding process and we ask for details of their ethical standards.
  • Our third-party support is for IT, marketing, corporate and finance facilities and is subject to legal contracts which includes Modern Slavery.
  • We review our modern slavery statement and our Compliance Monitoring matrix annually
  • We publish our commitment to tackle modern slavery policy on our website.
  • We will continue to enhance how we engage with new suppliers: If they’re subject to the ModernSlavery Act 2015, we require them to provide a link to their own website statement
  • The introduction of a new Supplier and Contract Management System allows us to check, and ifnecessary, challenge, the compliance of our suppliers.

7. Monitoring

We monitor our risks in this area annually through the use of relevant key performance indicators, including:

  • The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements,
  • The percentage of clients who sign up to an appropriate code or provide their own modern slavery statements,
  • The amount of time spent on audits, re-audits, spot checks, and related due diligence, and the level of modern slavery training and awareness amongst our staff.

8. Recommeded Reading

We would also recommend reading The Company Modern Slavery and Human Trafficking policy in conjunction with our other related policies which can be requested from our Office Manager, including:-

  • Corporate Social Responsibility policy,
  • Anti-bribery policy, and
  • Whistle-blowing policy.

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