modern slavery act

Introduction

This statement sets out Safetell Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financialyear May 2019 to April 2020.

As part of the Physical Security sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Definitions

Human Trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced Labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

Harmful Child Labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Organisational structure and supply chains

This statement covers the activities of Safetell Limited:

The Company is principally engaged in the design, manufacture and supply of products and services for the security of assets and personnel. The Company comprises of two divisions:

  • Design and installation of fixed and reactive security screens, reception counters, cash management systems and associated physical security equipment;
  • and Service and maintenance of the above equipment, as well as CCTV systems and locks.

Customers range from leading blue-chip organisations to single sites, including banks and building societies, post offices, police forces, railway companies, local authorities and Government departments, petrol outlets, hospitals, convenience stores, retailers and supermarket chains. The market varies across the product range.

Safetell’s supply chain is primarily from within the United Kingdom witha few suppliers from Europe.

Countries of operation and supply

Safetell only operates in the United Kingdom but supplies products to end users in various countries.

The following is the process by which the Company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Safetell supplies products to contractors and end users directly in the United Kingdom and because all companies we supply are registered business within the United Kingdom we assess that these contractors and end users are not high risk in relation to slavery or human trafficking.
  • Due to the nature of the security products we manufacture and the sensitive nature of the installations abroad we are not always informed of the end destination of the products. These products are supplied to United Kingdom registered security companies that export the products to their projects abroad. Our security products provide security and safety to people and assets within buildings and normally only form a part of a much larger construction contract and we have no or little impact on the design and eventual use of the building. With all these projects, we will obtain written confirmation from the purchasing Company that they are aware of The Modern Slavery Act 2015 and complete our customer questionnaire before we supply any products for export.

High-risk activities

Safetell do not consider any of the organisations activities within the United Kingdom to be at high risk of slavery or human trafficking.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: Safetell is part of the Newmark Security group and listed on the AIM Market (AIM)and all group policies are developed by the Human Recourses department with input and final approval by the board of Directors.
  • Risk assessments: Safetell recognises its responsibility to Human Rights and Modern Slavery and includes this into the risk assessment when engaging with potential new clients not based within the United Kingdom or when procuring products from countries outside the United Kingdom or European Union.
  • Investigations/due diligence: Due diligence in assessing new customers or suppliers remains with the Directors within Safetell and proper investigation will be completed if suspected instances of slavery and human trafficking are found.
  • Training: All staff are made aware of this policy and this is included in the new staff induction training as well as forming part of the employee handbook and additional policies which are updated and issued regularly to all employees.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy. The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact Human Resources or a Director.
  • Employee Handbook. The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier/Procurement code of conduct. All suppliers are assessed through the ISO 90001:2008 quality management policy procedure. The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship. All suppliers will be made aware that Safetell will not be associated with organisations that are known or found guilty of slavery or human trafficking and this will be communicated to all suppliers every year on the 30th April which coincides with our financial year end. Safetell will send the suppliers a copy of the Policy Statement and request a written reply that the supplier does not partake in slavery or human trafficking.
  • Recruitment Commitment. The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. All employees of the business are required to show proof of their right to work along with Security Vetting taking place up to BS7858:2002 standards. By ensuring that Recruitment agencies used are members of the Recruitment and Employment Confederation (REC), in turn the professional body sets standards to be followed in the recruitment process.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • evaluating the modern slavery and human trafficking risks of each new supplier this may be part of a more general human rights or labour rights assessment;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation will:

  • develop a system for supply chain verification expected to be in place by 1st January 2020, whereby the organisation will evaluate potential suppliers before they enter the supply chain; and
  • review its existing supply chains expected to be completed by 1st January 2020, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires management and all staff who are responsible for procurement within the organisation to be made aware ofmodern slavery as part of the induction process.

The organisation’s modern slavery training covers:

  • the issue of this Policy statement;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training relevant staff, the organisation has raised awareness of modern slavery issues by circulating this policy statement by email and including awarenessin the new employee Induction programme.

The communication explains to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.