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PHONE: 01420 543 222E-MAIL: sales@specialistdoorsolutions.com

Modern Slavery, Trafficking & Illegal Workers Policy

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Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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. 

Specialist Door Solutions Limited 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.

Specialist Door Solutions Limited 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 our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we 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.

 

Responsibility for this policy

Specialist Door Solutions Limited Directors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligations. The Operations Manager 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.

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.

 

Compliance with this policy

All Specialist Door Solutions employees must 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 at Specialist Door Solutions or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees must notify the HR Manager or the Operations Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. Employees 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 employees believe or suspect a breach of this policy has occurred or that it may occur, they must notify us, or they may report it in accordance with our Whistleblowing Policy as soon as possible. If an employee is 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, it should be raised with HR or the Operations Manager.

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. Specialist Door Solutions Limited is 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 an employee believes that they have suffered any such treatment, they should inform the HR Manager or Operations Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure.

 

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 

Our supply chains

Our supply chains include the sourcing of raw materials principally related to the provision of manufacturing of internal doors and Hygienic Wall Protection.

Our anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

 

Due diligence processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk:

  • Where possible we build long standing relationships with all our suppliers and make clear our expectations of business behaviour.
  • With regards to national or international supply chains, our point of contact is preferably with a UK company or branch, and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
  • We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

 

Supplier adherence to our values

We have a zero-tolerance approach to Slavery and Human Trafficking. We expect all those in our supply chain and contractors to comply with our values. The Directors have been briefed on the subject and it is discussed in management meetings to raise awareness and reviewed annually.

 

Our effectiveness in combatting Slavery and Human Trafficking

We use the following KPIs to measure how effective we have been to ensure that Slavery and Human Trafficking is not taking place in any part of our business or supply chains:

  • Annual reviews in management meetings.
  • Use of labour monitoring and payroll systems.
  • Communication and personal contact with the supply chain and their understanding of, and compliance with, our expectations.

 

Illegal workers

We carry out appropriate VISA, Passport and DOB checks to ensure all employees are entitled to work in the UK in accordance with Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006. We adhere to the Home Office Right to Work Checklist:
  • Obtain original documents from list A or B of acceptable documents.
  • Check the documents are genuine, that the person presenting them is the prospective employee, the rightful holder and allowed to do the work for which they are being employed.
  • We take a clear copy of each document in a format which cannot later be altered and retain securely: electronically or hardcopy. We record the date on which the checks were made.

All related verified documentation is retained for a minimum of 2 years after the individual has ceased employment with Specialist Door Solutions Limited. Due Diligence Processes for Slavery and Human Trafficking Specialist Door Solutions undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.

Specialist Door Solutions Limited due diligence process includes the building of long-standing relationships with suppliers and making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier and/or invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Specialist Door Solutions Ltd may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

This statement is made pursuant to 54(1) of the Modern Slavery Act 2015 and constitutes our Specialist Door Solution Limited’s Slavery and Human Trafficking statement for the current financial year.

This policy does not form part of an employee’s contract of employment and maybe changed at any time to improve its effectiveness or due to new legislation.