Modern Slavery, Illegal Workers and Human Trafficking Policy

Modern slavery is an umbrella term that encompasses a wide spectrum of crime, including human trafficking, slavery, servitude, and forced labour. The term refers to situations of exploitation that a person cannot leave due to coercion, use of force, abuse of vulnerability, deception or other means. It is the illegal exploitation of people for personal or commercial gain and is a violation of fundamental human rights.

Some estimates suggest that there are approximately 50 million people living in slavery across the world, many of whom will be working to produce the goods and services which are bought and sold every day.

The International Labour Organisation estimates hundreds of billions of illegal profits are generated by traffickers per year. Unscrupulous businesses who use slave labour undercut businesses and if this horrendous crime is to be eradicated from the UK and the rest of the world, government and businesses must work together

At Scutum we are committed to maintaining the highest standards of ethical conduct and social responsibility. We strongly condemn modern slavery, human trafficking, and the employment of illegal workers. This policy outlines our approach to preventing these practices and ensures compliance with relevant legislation, including Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006 and the Home Office Guidance Comprehensive Guidance for Employers on preventing illegal working.

1. Modern Slavery 

Modern slavery encompasses various forms of exploitation, including slavery, servitude, forced or compulsory labour, and human trafficking.

2. Human Trafficking

Human trafficking involves the recruitment, transportation, transfer, harbouring, or receipt of persons through force, coercion, or deception for the purpose of exploitation.

3. Illegal Workers

Illegal workers refer to individuals who do not have the legal right to work in the country where they are employed.

1. Senior Management

Senior management is responsible for setting the tone and ensuring a zero-tolerance approach to modern slavery, human trafficking, and the employment of illegal workers. They must foster a culture where everyone understands the importance of compliance with this policy.

2. Human Resources

The Human Resources department is responsible for implementing and monitoring compliance with this policy. They will oversee the recruitment process, maintain necessary records, and ensure that all employees are eligible to work legally.

3. Employees

All employees must familiarise themselves with and adhere to this policy. They should report any concerns related to modern slavery, human trafficking, or suspicions of illegal workers to the Human Resources department.

1. Eligibility to Work

All individuals employed by Scutum must provide satisfactory evidence of their eligibility to work in accordance with the Immigration, Asylum & Nationality Act 2006. This includes verifying their identity and checking their right to work in the United Kingdom

2. Document Verification

We will conduct thorough checks to verify the authenticity of documents provided by potential employees. This includes verifying passports, visas, work permits, and any other required documentation. Documents will be retained for a least 2 years once an individual has left the company.

3. Nationality Identification

To ensure compliance with legal requirements, we will implement appropriate procedures to identify the nationality of foreign workers. This may involve collecting data such as passport information, visa details, or immigration status. The collection and storage of this data will be in accordance with applicable data protection laws.

4. Temporary, Seasonal Workers or Subcontractors

We expect our subcontractors and Temporary staff to share our commitment to preventing modern slavery, human trafficking, and the employment of illegal workers. We will assess their compliance with this policy and take necessary actions to address any concerns. We work directly with recruiting agencies and ensure periodic checks and controls of their right to work

1. Training

All employees involved in the recruitment and employment processes will receive appropriate training to understand the risks associated with modern slavery, human trafficking, and the employment of illegal workers. This training will focus on identifying signs of exploitation, understanding legal obligations, and reporting any suspicions or concerns.

2. Non-Retaliation

We will ensure that individuals who report concerns in good faith are protected from retaliation. Any form of victimisation or discrimination against whistleblowers will not be tolerated.

1. Responsibilities

Our Group recognises that we have a responsibility to review ongoing internal practices in relation to our labour force, as well as our supply chains. Our Group does not knowingly enter into business with other organisations, in the United Kingdom or abroad, which knowingly support or are found to involve themselves in slavery, servitude, forced or compulsory labour, or abuse of power over vulnerable individuals. 

1. Compliance

We are committed to complying with all relevant legislation, including Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006 and the Home Office Guidance Comprehensive Guidance for Employers on preventing illegal working. We will regularly review and update our procedures to ensure ongoing compliance.

2. Monitoring

Regular audits and reviews will be conducted to monitor compliance with this policy. These audits may include document checks, interviews with employees, and assessments of our subcontractors and suppliers.

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or termination of business relationships with subcontractors or suppliers.

This policy will be communicated to all employees, subcontractors, and suppliers. It will be reviewed periodically to ensure its effectiveness and relevance.

This policy aims to create a work environment free from modern slavery, human trafficking, and the employment of illegal workers. We are committed to continuously improving our practices, educating our employees, and working collaboratively with relevant stakeholders to combat these illegal and unethical activities.