Modern slavery has no place here at Delyth Jones Consulting Limited. It is a crime and a violation of fundamental human rights. It can take 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 – be that of a child or an adult – by another to exploit them for personal or commercial gain.
We do not tolerate modern slavery within any part of our business.
As we are an SME, and are a business with a turnover under £36 million, we are not legally obliged to make a disclosure as is required under the Modern Slavery Act 2015. Irrespective of legal obligations, we’re committed to acting ethically in all our business dealings and relationships. We implement and enforce systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We expect the same high standards from all of our contractors, suppliers and business partners. As part of our contracting processes, in the coming year, we will include anti-slavery clauses in our contracts to remove the risk of having compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children within the fulfilment of any of our supply chains and contracts. We expect that our suppliers will hold their 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 the policy
The Management at Delyth Jones Consulting has responsibility for:
· ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it;
· 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;
· ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
Compliance with the policy
On joining our company, each employee is made aware of this policy and how 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 under our control.
Our employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. If there’s a belief or suspicion that a conflict with this policy has occurred or may occur in the future, then our employees know to notify their line manager OR a company Director immediately.
Our 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.
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. We are committed to ensuring no one suffers any detrimental treatment as a result 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.
Communication & 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 regularly (annually or as necessary). Our zero-tolerance approach to modern slavery is also communicated to our suppliers, contractors and business partners at the outset of our business relationship with them.
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 terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
We will monitor this key area to help maintain the high ethical standard by which we run our business.
Signed by Delyth Jones, Director,
Delyth Jones Consulting
May 2024.
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