The potential risk from our contractors is greater and therefore we expect high
standards from all our contractors, suppliers and other business partners. Part of our supply chain and compliance management processes include specific prohibitions and compliance checks against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
We monitor the approach of our contractors in respect of compliance with the Modern Slavery Act by several means including:
- Checking the response to compliance questionnaires
- Carrying out contractor site audits to assess the policy and practice in respect of Modern Slavery Act
- Compliance Checking the Modern Slavery Policy where the contractor has an obligation to produce this
- Monitoring legitimate sources for any enforcement action taken against contractors for breach of Modern Slavery legislation.
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 party to exploit them for personal or commercial gain. CREATIVE WASTE SOLUTIONS LTD 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. This includes implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the CREATIVE WASTE SOLUTIONS LTD business or supply chains. This policy applies to all persons working for CREATIVE WASTE SOLUTIONS LTD 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, but we may amend it at any time.
Responsibility for the policy
The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Board will furthermore review the policy periodically to ensure compliance with good practice and legislative developments. The Board shall also ensure that this policy is entirely compatible with all other CREATIVE WASTE SOLUTIONS LTD policies and procedures including Corporate Social Responsibility.
Line managers 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. Any employee may raise comments, suggestions and queries about this policy or it’s effective implementation and these will be considered by the Board in the interests of inclusion and continual improvement.
Compliance with the 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 CREATIVE WASTE SOLUTIONS LTD. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy or report any occurrence of an actual or potential breach by others, whether fellow employees or external parties such as contractors. All employees must notify their immediate manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. Failure to do so may result in disciplinary proceedings. Suppose any employee is unsure about whether a particular act, the treatment of workers or their working conditions at any level of the supply chains constitutes or may constitute any of the various forms of modern slavery, the concern must be raised
with their manager or any Director. CREATIVE WASTE SOLUTIONS LTD aims 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 that no person 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 CREATIVE WASTE SOLUTIONS LTD business including supply chains. Detrimental treatment in this context 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 a business Director immediately. If the matter is not remedied for the employee concerned, they should raise it formally using CREATIVE WASTE SOLUTIONS LTD Grievance Procedure.
Communication and awareness of this policy
Training on this policy, and on the risk that CREATIVE WASTE SOLUTIONS LTD business faces from modern slavery in its operations and supply chains, forms part of the induction process for all individuals who work for CREATIVE WASTE SOLUTIONS LTD, and regular awareness will be provided as necessary. CREATIVE WASTE SOLUTIONS LTD has a zero-tolerance approach to modern slavery and this will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this Policy
Any CREATIVE WASTE SOLUTIONS LTD employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. CREATIVE WASTE SOLUTIONS LTD may terminate their relationship with any individual, contractor, supplier, business partner or other organisation working on behalf of CREATIVE WASTE SOLUTIONS LTD or who supplies products and services to CREATIVE WASTE SOLUTIONS LTD or directly to CREATIVE WASTE SOLUTIONS LTD Customers.