1/ Introduction
This Policy sets out the steps WM Promus will take to comply with the Modern Slavery Act 2015 and our commitment to acting ethically and with integrity in our organisations relationships across the UK and internationally.
This page sets out the policy of WM Promus with the aim of the prevention of opportunities for modern slavery to occur within the organisation or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.
Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). The Act is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
From 29 October 2015, the Transparency in Supply Chain Provisions (source: Modern Slavery Act, 2015, Section 54(1), requires businesses to ‘publish an annual statement if they have an annual turnover above a threshold of £36 million’. Although WM Promus does not meet the financial threshold for the need to publish an annual statement the company is still cognizant of the need to support our suppliers and customers in mitigating the risks of Modern Slavery.
WM Promus statement is made in relation to this legislative requirement and confirms the steps taken to ensure that slavery and human trafficking are not taking place in the organisation.
We operate several policies which reflect our commitment to acting properly in all of our organisational relationships and to implementing and enforcing effective systems and controls. Our policies which contribute to minimising the risk of modern slavery and human trafficking in our organisation and our supply chain include our:
- Recruitment policy
- Whistleblowing policy
- Safeguarding policy
- Confidentiality policy
We will continue to review our policies to ensure that they are effective and appropriate. Subject to changes in legislation, this Policy will be reviewed and updated accordingly.
Slavery can take many forms. These include:
- Child trafficking
- Forced labour
- Forced marriage
- Sexual exploitation
- Criminal exploitation
- Domestic servitude
- Labour exploitation
- Organ harvesting
WM Promus will not tolerate slavery in any aspect of our organisation. We hold our supply chains and ourselves accountable and we will ensure compliance with the provisions of the Modern Slavery Act 2015 in relevant aspects of our work.
2/ Policy Outline
This policy document provides an overview of our zero-tolerance approach to modern slavery. We assess risks across supply chains and have amended our procedures to ensure that our contractors, consultants, suppliers and downstream partners (who directly implement our projects), in areas where a potential risk may occur, actively work towards eradicating modern slavery. Given the size of the organisation and the areas in which we engage we have determined that the risk to our organisation is very limited. The potential areas of risk will mainly relate to our supply chain and in all cases the organisations with which we engage have well established Anti-slavery policies. Nevertheless, the organisation still has an obligation to ensure that our supply chain maintains its integrity in respect of modern slavery and as such we will undertake regular reviews in this regard with our partners and organisations within our supply chain.
3/ Our Approach
To mitigate risk within our supply chains, we have implemented and communicated the following systems and controls:
- Identify and assess potential risk areas in our UK supply chains by conducting an organisation wide risk analysis
- Mitigate the risk of slavery in our supply chains by being open with suppliers on how we work together
- Ask third party providers for a copy of their Modern Slavery policy or statement. Where this is not available, we will ask third party providers to read and comply with ours. This will be carried out at the onboarding stage of all new suppliers.
4/ Risk Management
WM Promus mainly operates in the UK but the company does have partners and suppliers that operate outside the UK, thus we identified that we have potential exposure to risk. However, our Modern Slavery Policy and policies around recruitment, safeguarding and procurement ensures that we have effective controls in place to continually mitigate risk. Staff are encouraged to ‘speak up’ through our whistleblowing and confidentiality policies.
To manage this risk, we will work with suppliers and contractors to acknowledge our commitment to combat slavery by inserting relevant clauses into our contracts and agreements.
5/ Training and Awareness Raising
To ensure a high level of understanding of the risks of modern slavery, we annually review awareness and provide access to our Anti Slavery policy within our HR system which is accessible to all employees. WM Promus Safeguarding awareness drive includes the modern slavery policy and is available through the company HR management system. The updated policies will be made available to all staff. This is aimed at helping colleagues to better understand the risks and how we as an organisation are working to manage this and mitigate the risks of Modern Slavery,
6/ How to Report Modern Slavery Concerns
Colleagues who suspect incidents or signs of modern slavery in the UK should:
- In the first instance, all modern slavery crimes should be reported to the local police by dialling 999.
- If colleagues hold information that could lead to the identification, discovery and recovery of victims in the UK, they should contact the Modern Slavery Helpline 0800 0121 700.
- For more information, colleagues are advised to visit: unseenuk.org
- Alternatively, colleagues can make calls anonymously to Crimestoppers on 0800 555 111.
7/ Monitoring, Review and Performance Information
The monitoring and effectiveness of this policy will be managed by the senior management notably the General Manager.
- Recording and monitoring any incidents or reports made to us which conflict with our values.
- Treating all reports and incidents in line with our confidentiality policy.
- Reviewing and strengthening our centralised procurement processes and policy, taking into account a range of risks, including slavery and human trafficking.
8/ Contact
For any questions or concerns regarding this policy, please contact: enquiries@wmpromus.com
Note: WM Promus are not a relevant commercial organisation subject to Section 54 of the Modern Slavery Act 2015. However, this anti-slavery statement aligns with the act and it is published on our website.