MODERN SLAVERY POLICY

 

Structure, Business and Supply Chains

 

C&D acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These, as well as temporary workers, make up the supply chain within C&D Group Limited. We have zero tolerance to slavery. human trafficking and exploitation.  As of September 2017, over 40 million people are reported to be trapped in some form of slavery.  The main areas, but not limited to:

Domestic Servitude/ Sex Trafficking/ Forced Labour/ Bonded Labour/ Child Labour/ Forced Marriage.

 

C&D supply over 1,000 workers to 30 plus companies every week.  We employ 40 plus staff in 4 branches, plus on-site locations throughout the UK.  From time to time when skill shortages are particularly acute, C&D might recruit from the EU whilst always advertising vacancies in the UK.

 

Suppliers and candidates from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.

 

As part of the company’s due diligence processes into slavery, human trafficking and exploitation the supplier approval process will incorporate a review of the controls undertaken by the supplier. The company will not support any business knowingly involved in slavery, human trafficking or exploitation.

 

Policies and Procedures

 

The Board of Directors shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training etc) and investment to ensure that slavery, human trafficking and exploitation is not taking place within the organisation and within its supply chains.

 

This policy takes into account, and supports, all other policies, and procedures at C&D Group Limited. The implementation and operation of which underlines our commitment to our policies as well as our continuation of our Gangmaster’s Licence, which is highly relevant in this case.  As a licensed labour provider under the provisions of the Gangmaster Licencing Act 2004 we ensure we adhere to the main standards, which are all legal requirements to protect workers from poor treatment and exploitation, covering issues such as working hours, training, terms and conditions, the national minimum wage and transport to ensure labour providers meet the basic safety and welfare standards.  There are 8 standards covering the following subject areas:

 

  • Fit and Proper Test
  • Pay and Tax Matters
  • Prevention of Forced Labour and Mistreatment of Workers
  • Accommodation
  • Working conditions
  • Health and Safety
  • Recruiting Workers and Contractual Arrangements
  • Sub-Contracting and Using Other Labour Providers

 

As such we adhere to these 8 standards which collectively address our commitment to human rights and the elimination of all forms of forced and compulsory labour.

 

C&D are members of the Recruitment and Employment Confederation (REC).  The REC Code of Professional Practice has been created to ensure members of the REC conduct their business ethically, to the highest standards and promote good practice.

 

 

 

 

 

 

 

 It is binding on all corporate members.  The REC code requires higher ethical standards in 10 principles

 

  • Respect for Laws
  • Respect for Honesty and Transparency
  • Respect for Work Relationships
  • Respect for Diversity
  • Respect for Safety
  • Respect for Professional Knowledge
  • Respect for certainty of Engagement
  • Respect for prompt and accurate payment
  • Respect for Ethical International Recruitment
  • Respect for Confidentiality and Privacy

 

Copies of  this policy and the Modern Slavery Act 2015 are accessible electronically and can be obtained from the internal G:/Central Information/Company Policies.

 

Formal procedures concerning slavery, human trafficking and exploitation have been established, including disciplinary procedures where they are breached, Additional procedures ensure that this policy is understood and communicated to all levels of the company, and that it is regularly reviewed annually by the Directors to ensure its continuing suitability and relevance to the company activities. 

 

Processes to Assess and Manage Risk

 

All our recruiters observe the following practices to assess and manage risks:

 

  • Only interview candidates in approved location
  • Not allow candidates to complete registration documents on behalf of others
  • Not accept money, favours or any gifts at all from candidates or clients
  • Not loan any personal money to temporary workers
  • Notify a director when suspecting an individual of introducing candidates to a Company for personal gain
  • Not allow anyone other than an authorized person to choose which candidates are selected for work shifts
  • Not force or coerce temporary workers to work against their will
  • Not subject or threaten workers to physical or mental mistreatment
  • Treat candidates and clients with dignity and respect
  • Raise any knowledge or suspicions of illegal or dubious activities regarding clients, candidates or colleagues to a director immediately

 

Training

 

We adhere to standards of responsible conduct and train employees to treat each other with respect, and to adhere to laws, regulations and standards.  Training and referencing practices are undertaken as part of their induction programme, with refresher training as relevant laws and regulations occur.

 

Whistleblowing Policy

 

C&D employees are aware that they can voice any concerns confidentially with the Compliance Department or a member of the Board of Directors.

 

This policy statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes C&D’s slavery, human trafficking and exploitation statement.

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