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EdenhouseModern Slavery Statement

Modern Slavery Statement

1. Definitions

 This Policy has been drafted pursuant to Section 54, Part 6 of The Modern Slavery Act 2015 (MSA). The MSA covers four activities which are defined below:

Slavery Slavery involves the exercise of powers of ownership over a person
Servitude Servitude involves the obligation to provide services is imposed by the use of coercion.
Forced or compulsory labour Forced or compulsory labour involves coercion, either direct threats or violence or subtle forms of compulsion. The key elements are that work or service is exacted from a person under the menace of any penalty and for which the person has not

offered themselves voluntarily.

Human trafficking Human trafficking involves arranging or facilitating the travel of another person with a view to their exploitation.

Besides the four activities above, a person is considered to be affected by modern slavery if they are forced to work through mental or physical threat, owned or controlled by an employer through mental and/or physical abuse, de-humanised, treated as a commodity (bought or sold as property), physically constrained or has restrictions on their freedom of movement.

 

2. How is MSA relevant to Edenhouse?

Modern slavery is a complex and multi-faceted crime which affects communities on a global scale. Under the MSA, any company with a turnover more than £36m must produce an annual statement setting out steps taken to ensure modern slavery is not taking place. At Edenhouse, we are committed to ensure that there is no modern slavery or human trafficking in any of our supply chains and maintain a zero-tolerance approach. To ensure this happens, we must all play a vital part. Compliance is a must, not least because it is the law, but it also protects our workforce, reputation and procures good business ethic. At Edenhouse, we pay particular attention to:

  • our supply chains;
  • any outsourced activities, particularly to jurisdictions that may not have adequate safeguards;
  • cleaning and catering suppliers; and corporate

3. Our Responsibility

At Edenhouse, we as a firm, including managers and colleagues, have responsibilities to ensure our fellow workers are safeguarded, treated fairly with dignity and prevented from any exploitation under the MSA. Everyone must observe this Policy and be aware that turning a blind eye is unacceptable.

At Edenhouse, we will:

  • maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation;
  • publish an annual statement setting out our responsibilities to our employees and clients (see paragraph 6.1 below);
  • check our supply chains (see paragraph 6.2 below);
  • be clear about our recruitment policy (see paragraph 6.3 below);
  • lead by example by making appropriate checks on all employees, recruitment agencies, suppliers etc. to ensure we know who is working for us;
  • ensure we have in place an open and transparent grievance process for all staff; and
  • seek to raise awareness so that our colleagues know what we are doing to promote their

Managers will:

  • listen and be approachable to colleagues;
  • respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;
  • remain alert to indicators of slavery (see paragraph 6.4 below);
  • raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do; and
  • use their experience and professional judgement to gauge

All colleagues, irrespective of role, level or seniority, will:

  • keep their eyes and ears open – if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see paragraph 6.5 below);
  • follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated; and
  • tell us if you think there is more we can do to prevent people from being

4. Risks

 The principal areas of risk we associate with the MSA include:

  • supply chains;
  • recruitment through agencies;
  • general recruitment; and
  • other associated

These risks are managed through the procedures set out in this Policy.

5. Breach

Members of staff acknowledge that breaching this Policy may lead to disciplinary action which could result which dismissal. Edenhouse may at its sole discretion terminate its relationship with any individual or organisation that breaches this Policy.

6. Our Procedures

 The procedures followed at Edenhouse in pursuance of tackling the atrocities under the MSA are set out below:

6.1. Anti-Slavery Statement

 We publish an annual Anti-Slavery statement which incorporates our responsibilities to our employees, people working within our supply chain and our clients.

6.2. Supply Chains

 We thoroughly check supply chains to highlight factors of high risk, through methods including but not limited to due diligence and site inspections, to ensure modern slavery does not exist in their company and any risk of potential or actual slavery and/or human trafficking is reduced. We ensure our supply chains provide safe and fair working conditions for its employees.

All of our contractual documents, including supplier contracts, contain an anti-slavery clause which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.

6.3. Recruitment (In-house and External)

 In-house

All members of staff have a written contract of employment and receive minimum wage or above. Staff must confirm that they have not paid any direct or indirect fees to obtain work.

We ensure staff are legally eligible to work in the UK and maintain robust immigration checks.

We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).

We provide information to all new employees on their statutory rights including sick pay, holiday pay and any other benefits to which they may be entitled.

If we suspect a potential employee is being exploited, Recruitment or HR will follow our reporting procedures (see paragraph 6.5 below).

External

From time to time, Recruitment find candidates from external, specified and reputable recruitment agencies. To ensure the risk of any activity under the MSA is mitigated as far as possible, we thoroughly check and undertake due diligence on the external recruitment agencies before adding them to our panel agencies. This includes:

  • conducting background checks;
  • investigating reputation;
  • ensuring potential candidates have appropriate paperwork (e.g. work visas, permits and all other required documentation); and
  • ensuring the agency provides assurances that the appropriate checks have been made on potential candidates.

6.4. Identifying Slavery

There is no typical victim under the MSA; some victims do not understand when they have been exploited and how they are entitled to help and support. However, the following signs could indicate that someone may be a victim of slavery or trafficking:

  • The person is not in possession of their own passport, identification or travel
  • The person is acting as though they are being instructed or coached by someone
  • They allow others to speak for them when spoken to
  • They are dropped off and collected from
  • The person is withdrawn or they appear
  • The person does not seem to be able to contact friends or family
  • The person has limited social interaction or contact with people outside their immediate

This list is not exhaustive.

Despite a person displaying a number of the indicators above, they may not necessarily be a victim of slavery or trafficking. Generally, person’s circumstances should indicate that something is not quite right. If you have a suspicion, report it to your line manager in a first instance, and then to Recruitment and HR.

6.5. Reporting Slavery

 Talking to someone about your concerns may stop someone else from being exploited or abused. If you think you have identified a specific case of modern slavery, you should report it to your line manager at a first instance. Your line manager will, as necessary, report it to the Legal and Commercial team. If it cannot be dealt with internally, Edenhouse will notify the police on 101. If potential victims are in immediate danger, colleagues are encouraged to dial 999. Employees will be informed about the Modern Slavery Helpline from which they can gain further information and guidance on next steps.

Otherwise, you should discuss your concerns with Recruitment, HR or Legal and Commercial team who will decide a course of action and provide any further advice.

Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at a higher risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the affected individual, and as necessary arrange a meeting with the affected individual and Recruitment/HR/Legal and Commercial team before taking any further action.

6.6. Training

 At Edenhouse, we provide specialist training to those staff members who are closely involved in managing recruitment and our supply chains. General awareness training is also provided to staff.

6.7. Procedure Review

 Our procedures are reviewed on an annual basis and employees will be informed of any changes to any current policies.