The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains. The Seetec Group is committed to developing its’ social and environmental responsibilities and are fully committed to playing our part in eradicating modern slavery. We advocate for transparency and collaboration to eliminate the risks of modern slavery and ensure that we take appropriate action where necessary.
The Company’s committed to operating and promoting ethical and lawful business practices within the workplace. This is evidenced through our Investors in People Gold accreditation, IIP Health and Wellbeing award, Merlin and a Certified B Corporation®, OHSAS 18001 (International safety standard for occupational health and safety), ISO 14001 (minimising environmental impact) and we are a Disability Confident employer.
This statement refers to the financial year ending 31st March 2018. It sets out the steps taken by Seetec to prevent modern slavery and human trafficking in our own operations and supply chains.
Our Business areas and supply chains
Seetec Group is a Public and Business Services provider and operates across the UK and in the Republic of Ireland. This statement covers the activities of the Group which consists of Seetec Business Technology Centre, Seetec Employment and Skills Ireland, Outsource Training and Kent, Surrey and Sussex Community Rehabilitation Company.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
- Conducting supplier audits and / or assessments where general risks are identified
- Taking steps to improve suppliers' practices, including providing advice to suppliers and requiring them to implement action plans
- Invoking contractual remedies against suppliers that fail to improve their performance in line with their contractual requirements and / or any agreed action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Responsibility and Policies
Responsibility for the organisation's Corporate Social Responsibility initiatives, which includes anti-slavery, sits with the Group Executive Board and corporate risks are regularly reviewed by the Group Risk and Assurance Board.
Our approach to addressing modern slavery is supported by a number of organisational policies and we take any breach of our policies or allegations extremely seriously. In the last 12 months there have been no reported incidents in relation to modern slavery or human trafficking.
Modern Slavery Policy – sets out our commitment to preventing modern slavery or human trafficking in the delivery of our service and full support in the promotion of ethical and lawful business practices within the workplace.
Whistleblowing policy- encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Employee code of conduct - makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.
Our engagement process, Due Diligence, Contracts and Supply Chain Management Framework set out our commitment to ensuring that our supply chain adheres to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat their workers with dignity and respect, and act ethically and within the law at all times. The organisation works collaboratively with supply chain partners to ensure that they meet these and improve where required. However, serious violations of our code of conduct will lead to the termination of the business relationship.
HR Vetting and Compliance Policy – specifies that we use only reputable employment agencies and always verify the practices of any new agency before accepting workers from that agency. All employees, contractors and agency workers have their right to work in the UK verified. As an organisation we ensure that we adhere to legislation in relation to minimum age requirements, wages and the Working Time Directive.
Safeguarding Policy- outlines our commitment to providing a safe environment for our workforce and customers and the routes to escalate issues. We also have nominated safeguarding leads across the whole organisation to provide support and we operate a dedicated confidential Safeguarding phone line for external learners to report any causes for concern.
Seetec requires all employees working within the organisation to complete training on our organisational policies. As well as employee training, this year the we have focused on raising awareness of exploitation and abuse issues, including human trafficking, by running a group wide ‘see me, hear me, protect me- #I am not invisible’ safeguarding awareness campaign. This has included internal intranet articles distributing flyers to staff/putting up posters across the organisation's premises and signposting to external resources and contacts.
As part of our compliance review process, we have conducted site visits with our Supply Chain Partners to review their compliance against policies and regulations and where gaps have been identified, work with them to manage an action plan to address any such gaps.
Over the course of the next financial year we will continue to raise awareness and understanding the risk of modern day slavery within our business and enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers.
This statement has been formally approved by the Seetec’s Group Executive Board and signed on their behalf.