Introduction
This statement sets out Victoria Court actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
Victoria Court, including its associated and subsidiary companies, recognises that it has a responsibility under the Modern Slavery Act 2015 to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
Relevant Policies
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
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HR Policy – We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally, and are paid at least the national minimum wage. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 48 hours per week average unless the employee agrees.
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Purchasing Policy – The organisation is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls including but not limited to Victoria Court Group’s ‘Quality Management’, ‘Environmental’, ‘Ethical Code of practice’, ‘Anti-Bribery’ and ‘Modern slavery and Human Trafficking’ policies which fulfil legal and financial obligations and effectively manages commercial risk. Emphasis is placed on selecting suppliers and service providers that demonstrate recognisable environmental, sustainable, business integrity along with Corporate Social Responsible (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation, maintenance and promotion of information security, fair trade and acceptable corporate ethics.
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Recruitment Policy – The organisation uses only specified, reputable employment agencies to source agency workers and always verifies the practices of any new agency it is using before accepting workers from that agency.
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Whistleblowing Policy – We encourage all of our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of,Victoria Court. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
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Our values –Victoria Court values of Knowledge, Integrity and Action makes clear to our employees the actions and behaviour expected of them when representing Victoria Court. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Due Diligence
We undertake due diligence when considering taking on new suppliers, and review our existing suppliers on a periodic basis. Our due diligence and reviews include:
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Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
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Evaluating the modern slavery and human trafficking risks of each new supplier
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Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified
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Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Awareness-Raising Programme
As well as training employees, the organisation has raised awareness of modern slavery issues by circulating information to employees.
The information explained to relevant employees:
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The basic principles of the Modern Slavery Act 2015;
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How employers can identify and prevent slavery and human trafficking;
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What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
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What external help is available, for example through the Modern Slavery Helpline.
Board Approval
This statement has been approved by the organisation’s board of directors, who will review and update it annually. Our Executive Management team take responsibility for implementing this statement and its objectives. They will ensure adequate resources and investment to ensure slavery and human trafficking isn’t taking place within our organisation or within our supply chains.