Modern Slavery Act Statement
Anti - Slavery and Human Trafficking Statement for the 2018 Financial Year (April - March) - Updated April 2019
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Introduction from the Managing Director
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
Our Policy on Human Slavery and Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in any part of business or in our supply chains. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to prevent slavery and human trafficking 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 –
We employ a professional Human Resources Team who vet all applicants thoroughly and work closely with any agencies and 3rd parties who provide us with labour.
Where possible we build long standing relationships with our suppliers and 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 expect each entity in the chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain, ultimately to component manufacturers.
We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
We have embraced the Stronger Together Programme across our sites, and applaud the work being done to reduce forced labour and human trafficking in the UK. Our Human Resources Team have been trained in the exploitation of human labour and we have provided training to key personnel within the business. All employees and agency staff have received information regarding the Stronger Together principles and have mechanisms to increase the visibility of issues, for example through confidentially contacting the Human Resources Team 02393600003 .
We regularly assess risk related to human trafficking and forced labor associated with our supply base. Our preliminary assessment is based upon the commodity or service purchased, supplier quality performance , business location and the nature of the business transaction.
The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
Citrus classifies its suppliers as follows: 1) Goods for resale, 2) Direct materials, 3) Indirect purchases; consumables and services, e.g. cleaning and valeting.
Internal processes and procedures allow us to clearly identify high risk supply chains and/or areas within our supply chains where there is an increased risk of modern slavery. We have as such identified that one of their main areas of exposure has been identified as the outsourcing of valeting services . As a result we have included taking positive steps to ensure that our contract valeting Company is adhering to all our suppliers principles , included their management on our internal training program and have provided them with clear and concise directions with regards to the recruitment and assessment of their personnel.
Supplier Adherence to our Values
We expect all those in our supply chain and contractors comply with our values.
The Directors and Senior Managers are responsible for compliance in their respective departments and for their supplier relationships
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
This statement constitutes our group's slavery and human trafficking statement for the current financial year.
Daniel O'Brien Director