MODERN SLAVERY ACT 2015 POLICY STATEMENT
This document outlines Route 101’s modern day slavery policy, also known as an anti-modern slavery policy or human trafficking policy. It represents a formal document and guidelines that outlines our commitment to preventing and combating modern slavery in our operations and supply chains.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour (including child labour), debt bondage, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
Route 101 has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with any disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes. We check and insist partners include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
RESPONSIBILITY FOR THIS POLICY
Route 101 has overall responsibility for ensuring this policy complies with our legal and ethical obligations, international standards and conventions, and that all those under our control comply with it. We have 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.
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. Stakeholders 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 Managing Director who owns this policy.
We will achieve these aims by our initiative to identify and mitigate risk in the following ways (but not limited to):
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
COMPLIANCE WITH THIS POLICY
Staff must ensure that they read, understand, and comply with this policy. 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 with us.
Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy. They must notify their line manager or a company director as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. They are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If staff believe or suspect a breach of this policy has occurred or that it may occur, they must notify their line manager or a company director or report it in accordance with our Whistleblowing Policy as soon as possible.
With the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
If staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with their line manager or a company director.
COMMUNICATION AND AWARENESS OF THIS POLICY
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and our staff. Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. Supplier engagement and collaboration involves how we value suppliers and stakeholders whilst emphasising the need for and importance of working with suppliers and other stakeholders to promote awareness, transparency, and compliance with this policy.
We are an SME with no parent company, subsidiaries or affiliated entities. However, we have a number of large third-party vendor suppliers with whom we work regularly, and we fulfil our obligations under the slavery act by working in a sharing and collaborative way.
We aim to encourage openness and 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 because 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 supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If staff believe that they have suffered any such treatment, they should inform their line manager immediately.
BREACHES OF THIS POLICY
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may also terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached. Additional procedures ensure that this policy is understood and communicated to all levels within Route 101, and that it is regularly reviewed by the directors to ensure its continuing suitability and relevance to the company’s activities.
Our aim is to identify our responsibility by alerting staff to the risks, however small, in our business and in the wider supply chain. Staff are expected and encouraged to report concerns to management, where they are expected to act upon them.
ENFORCEMENT OF THIS POLICY
We will from time to time conduct due diligence exercises on our suppliers, contractors, and business partners. As part of this exercise, we check that their policies are updated at least annually and signed by a senior representative of their respective organisations.
Other prevention and mitigation strategies include regular audits, conducting employee training, and engaging with suppliers to ensure compliance. We establish clear reporting mechanisms for suppliers and employees to raise concerns and suspicions related to modern slavery and we encourage a culture of openness and accountability.
Where a concern is raised our appointed director will follow the defined investigation process for any raised or identified concerns and will take the appropriate action against violations, and provide remedies to victims, where applicable.
We communicate our efforts and progress in combating modern slavery through public statements, reports, and other relevant channels, including our website. We review our monitoring of others and the effectiveness of our policy, making any necessary improvements based on lessons learned and changes in the operating environment.
This policy is in accordance with Section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.