Anti-Slavery and Human Trafficking Policy and Procedure

 

This Lucketts Group Policy is approved by the Directors Board; it represents the Lucketts Group Board’s direction to the business on this topic. Compliance with this policy is mandatory through aligning Lucketts Group Management System processes and people behaviours to the commitments below.

 

Policy Statement

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, managers, driving staff, casual workers, agency workers, volunteers, agents, contractors and suppliers.

The Lucketts 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 organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

 

Our Commitment

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:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains;

• The prevention, detection and reporting of modern slavery in any part of our organisation 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 Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking;

• Consistent with our risk-based approach we may require:

• 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 Code of Conduct.

• If we find that other individuals or organisations 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.

 

Policy Compliance

If you fail to comply with the above rules on dress, appearance and personal hygiene, this is a serious matter and will be dealt with in accordance with the Company’s disciplinary procedure.

 

Review of policy and procedure

The Lucketts Group policies and procedures aim to ensure that employees are aware of, and confident that, the employer is complying with current legislation and is protecting the interests of both the needs of the business and the employee. In this respect, it may be appropriate to modify existing policies and/or procedures from time to time to reflect changes as appropriate, and this policy will be reviewed as necessary by designated Group Directors, and/or by personnel as delegated by the Directors Group.

 

Equality impact assessment (EIA)

It is considered that the Company’s recruitment processes meet the requirements under Equality legislation and is delivered in a fair and equal approach.

 

Equality Impact Assessment – initial screening – Relevant Equality Area	Does the Policy or its implementation?			Does the Company need to proceed to full EIA if in doubt then progress to full screening)
	Breach Equalities Legislation?	Affect different groups in different ways (both positive and negative)	Promote equality/good relations?
Gender	No	No	Yes	No
Race	No	No	Yes	No
Disability	No	No	Yes	No
Sexual Orientation	No	No	Yes	No
Religion and Beliefs	No	No	Yes	No

 

September 2018