Title: Modern Slavery
Category: Associated Policies 011
Last updated: 03/09/2024 by Danni Fraser-pickard
Approved by:

Nick Bell - Group Managing Director on 25/10/2024

Version: 1.1.3

03/09/2024 10:27:40

@@ -1,3 +1,4 @@
-[COMPANY] Trading as
-[COMPANYTA] [COMPANYREG]
+[COMPANY] - Trading as
+[COMPANYTA] 
+

02/09/2024 14:29:20

@@ -4,3 +4,3 @@
 
-#MODERN SLAVERY POLICY
+# MODERN SLAVERY POLICY
 
@@ -8,7 +8,6 @@
 
+## Policy Statement
+For the purpose of this policy, The RK Bell Group, also known as RK Bell, incorporates RK Bell Ltd, RK Bell Projects Ltd, and Gworks Surfacing Ltd.
 
-##Policy Statement
-For the purpose of this policy, The RK Bell Group, also known as RK Bell, incorporates RK Bell Ltd, RK Bell Projects Ltd & Gworks Surfacing Ltd.
-
-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, contractors and suppliers.
+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, contractors, and suppliers.
 
@@ -17,28 +16,29 @@
 
-######Modern Slavery and Human Trafficking
-Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
 
-######Commitments
-We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
+###### Modern Slavery and Human Trafficking
+Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
+
+###### Commitments
+We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
 
--###TAB###We have a zero-tolerance approach to modern slavery in our Company and our supply chains.
--###TAB###The prevention, detection and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
--###TAB###We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
--###TAB###We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our procedures, which sets out the minimum standards required to combat modern slavery and trafficking. 
--###TAB###Consistent with our risk-based approach we may require:
- -###TAB###employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our procedures
- -###TAB###Suppliers engaging workers through a third party to obtain that third party's agreement to adhere to this policy
--###TAB###As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our procedures.
--###TAB###If we find that other individuals or Companys working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
+- We have a zero-tolerance approach to modern slavery in our Company and our supply chains.
+- The prevention, detection, and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
+- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
+- We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our procedures, which set out the minimum standards required to combat modern slavery and trafficking.
+- Consistent with our risk-based approach, we may require:
+ - Employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our procedures.
+ - Suppliers engaging workers through a third party to obtain that third party's agreement to adhere to this policy.
+- As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our procedures.
+- If we find that other individuals or companies working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
 
-######Whistleblowing
-We encourage all our employees at all levels, directors, officers, agency workers, seconded workers, contractors and suppliers to report any concerns related to the direct activities, or the supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have a concern can complete our confidential disclosure form.
+###### Whistleblowing
+We encourage all our employees at all levels, directors, officers, agency workers, seconded workers, contractors, and suppliers to report any concerns related to the direct activities or the supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation. Employees, customers, or others who have a concern can complete our confidential disclosure form.
 
-######Supplier/Procurement code of conduct
-The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.
+###### Supplier/Procurement Code of Conduct
+The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers' working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.
 
-######Recruitment/Agency workers policy 
-The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. 
+###### Recruitment/Agency Workers Policy
+The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
 
-######Training
+###### Training
 The Company requires all staff/supply chain managers/HR professionals within the Company to complete training on modern slavery.
@@ -46,13 +46,10 @@
 The Company's modern slavery training covers:
--###TAB###our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
--###TAB###how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
--###TAB###how to identify the signs of slavery and human trafficking;
--###TAB###what initial steps should be taken if slavery or human trafficking is suspected;
--###TAB###how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
--###TAB###what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
--###TAB###what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
--###TAB###what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.
-
-
-
+- Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline.
+- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
+- How to identify the signs of slavery and human trafficking.
+- What initial steps should be taken if slavery or human trafficking is suspected.
+- How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
+- What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority, and "Stronger Together" initiative.
+- What messages, business incentives, or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
+- What steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.

02/09/2024 13:33:39

@@ -1,3 +1,3 @@
 [COMPANY] Trading as
-[COMPANYTA]
+[COMPANYTA] [COMPANYREG]
 
@@ -23,11 +23,11 @@
 
--###TAB###We have a zero-tolerance approach to modern slavery in our Company and our supply chains.
--###TAB###The prevention, detection and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
--###TAB###We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
--###TAB###We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our procedures, which sets out the minimum standards required to combat modern slavery and trafficking. 
--###TAB###Consistent with our risk-based approach we may require:
- -###TAB###employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our procedures
- -###TAB###Suppliers engaging workers through a third party to obtain that third party's agreement to adhere to this policy
--###TAB###As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our procedures.
--###TAB###If we find that other individuals or Companys working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
+- We have a zero-tolerance approach to modern slavery in our Company and our supply chains.
+- The prevention, detection and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
+- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
+- We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our procedures, which sets out the minimum standards required to combat modern slavery and trafficking. 
+- Consistent with our risk-based approach we may require:
+ - employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our procedures
+ - Suppliers engaging workers through a third party to obtain that third party's agreement to adhere to this policy
+- As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our procedures.
+- If we find that other individuals or Companys working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
 
@@ -46,10 +46,10 @@
 The Company's modern slavery training covers:
--###TAB###our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
--###TAB###how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
--###TAB###how to identify the signs of slavery and human trafficking;
--###TAB###what initial steps should be taken if slavery or human trafficking is suspected;
--###TAB###how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
--###TAB###what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
--###TAB###what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
--###TAB###what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.
+- our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
+- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
+- how to identify the signs of slavery and human trafficking;
+- what initial steps should be taken if slavery or human trafficking is suspected;
+- how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
+- what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
+- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
+- what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.

MODERN SLAVERY POLICY

Policy Statement

Modern Slavery

RK Bell Group - 10596233 - Trading as RK Bell Ltd 00587692 - RK Bell Projects Ltd 06637268- Gworks Surfacing Ltd 10596233

MODERN SLAVERY POLICY

Policy Statement

For the purpose of this policy, The RK Bell Group, also known as RK Bell, incorporates RK Bell Ltd, RK Bell Projects Ltd, and Gworks Surfacing Ltd.

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, contractors, and suppliers.

The RK Bell Group strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our Company or in any of our supply chains. We expect that our suppliers will hold their suppliers to the same high standards.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our Company and our supply chains.
The prevention, detection, and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our procedures, which set out the minimum standards required to combat modern slavery and trafficking.
Consistent with our risk-based approach, we may require:
- Employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our procedures.
- Suppliers engaging workers through a third party to obtain that third party's agreement to adhere to this policy.
As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our procedures.
If we find that other individuals or companies working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Whistleblowing

We encourage all our employees at all levels, directors, officers, agency workers, seconded workers, contractors, and suppliers to report any concerns related to the direct activities or the supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation. Employees, customers, or others who have a concern can complete our confidential disclosure form.

Supplier/Procurement Code of Conduct

The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers' working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.

Recruitment/Agency Workers Policy

The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Training

The Company requires all staff/supply chain managers/HR professionals within the Company to complete training on modern slavery.

The Company's modern slavery training covers:

Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline.
How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
How to identify the signs of slavery and human trafficking.
What initial steps should be taken if slavery or human trafficking is suspected.
How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority, and "Stronger Together" initiative.
What messages, business incentives, or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
What steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.

Reviewed: 03/09/2024
v1.1.3

Approved by: