Modern Slavery and Human Trafficking Policy
Introduction:
Space 2B You is committed to ensuring the health, safety, and welfare of all employee’s contractors, clients, public and maintaining high standards.
This policy is to be read in conjunction with Risk Management Policies, Risk Management guide, Safeguarding Policy, Equality, Diversity and Human Rights Policy, Codes of Conduct Policy, Whistleblowing and Confidentiality Policy.
All Space 2B You staff and Contractors must ensure they always uphold this policy.
It is Space 2B You’s responsibility to ensure this policy is implemented and informs all decision making.
Modern slavery is a serious and organised crime that causes significant harm to victims and communities. It is the illegal exploitation of people for personal or commercial gain, and involves people being coerced and forced into providing a service to others. It is a crime that affects people of all genders, ages (including children) and ethnicities and is a violation of fundamental human rights. It has been suggested, there are approximately 40 million people living in slavery across the world with the Home Office estimating over 10 thousand potential victims in the UK in 2013.
Zero Tolerance:
Space 2B You adopts zero tolerance to modern slavery and human trafficking, and all forms of corruption and bribery, directly and indirectly, associated with these criminal acts. While no such abuse is tolerated, an open and transparent approach is required by Space 2B You, Staff, Contractors, and suppliers, to ensure we take steps to identify and tackle any instances of modern slavery.
Modern slavery is so pervasive it may exist within the organisations, suppliers, commissioners, and services Space 2B You work with. Space 2B You is committed to ensuring staff, contractors, clients, and families accessing Space 2B You services are protected from criminal activity, exploitation, or harm.
Space 2B You fully supports the government’s objectives to eradicate modern slavery and human trafficking.
Space 2B You’s Codes of Conduct policy states all staff, contractors and clients will be treated with respect, dignity, and fairness. Therefore, ensuring the highest ethical standards of integrity, courtesy, and mutual respect.
Definitions:
Modern slavery is the term used within the UK and is defined within the Modern Slavery Act 2015 (the ‘Act’). The term is 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.
Policy Aims:
This policy provides a framework to ensure:
All staff and contractors understand and are aware of their responsibilities in relation to modern slavery.
The development of a strategic approach to identifying and tackling any modern slavery
The implementation of robust and transparent processes.
Reporting of instances (or concerns) of modern slavery.
Scope:
This policy applies to every person working with Space 2B You regardless of position and level of responsibility. Therefore, each staff member should have a clear understanding of this policy to prevent situations from arising that may impact the integrity of Space 2B You.
Responsibilities and Accountabilities:
Space 2B You recognises that it is responsible for promoting ethical business practices and policies that protect staff, contractors, clients, and the public from being abused or exploited.
The prevention, detection and reporting of modern slavery in any part of Space 2B You or its supply chain is the responsibility of all those working for us or on our behalf. Staff or Contractors must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy. Therefore, this policy applies to all persons working for Space 2B You, in any capacity, including employees at all levels, directors, contractors, employed staff, agency workers, trainees, work experience and volunteers.
Space 2B You Directors have an overall responsibility for ensuring this policy complies with legal and ethical obligations, and all staff and contractors comply with it. In addition, Directors are responsibility for the day-to-day implementation of this policy, monitoring its use and effectiveness, dealing with any related queries, and auditing internal systems and procedures to ensure they are effective in countering modern slavery. Furthermore, they are responsible to ensure partnerships, commissioners and supply chains comply with Modern Slavey Act 2015.
Organisations, commissioner, partnerships, and supply chains Responsibilities:
Space 2B You requires all organisations, commissioner, partnerships, and supply chains to:
fully comply with the Modern Slavery Act 2015.
Are clear, transparent, accountable, and auditable.
Are free from ethical ambiguities.
Space 2B You expects all organisations, contractors, commissioners, partnerships, and suppliers to operate to the highest level of ethical standards and will hold their own suppliers to the same high standards.
Contractors who supply goods or services deemed to be at particular risk of modern slavery may be invited to share the Modern slavery and human trafficking policy with Space 2B You.
Space 2B You as part of their auditing process will invite contractors, suppliers, partnerships, and commissioners to share the Modern slavery and human trafficking policy with Space 2B You. This audit will help Space 2B You to assess com capacity to manage and prevent the risks of modern slavery and to improve protections and reduce the risk of exploitation of staff in their supply chains.
Space 2B You acknowledges that organisations, commissioner, partnerships, and supply chains may be at different stages of their journey towards having more ethical supply chains but expects to see them demonstrate continuous improvement in how modern slavery risks are mitigated.
Space 2B You may require organisations, commissioner, partnerships, and supply chains who engage workers through a third party to obtain that third party’s agreement to adhere to this policy and demonstrate how they seek to tackle any Modern Slavery within their supply chain.
Awareness and Training:
Space 2B You will raise awareness of this policy and the Modern Slavey Act 2015 by:
Notifying partnerships, commissioners, and other organisations of the framework with which we regularly engage.
This policy will be discussed with all staff and contractors during supervision and team meetings.
The policy will be published on the Space 2B You website and available to all staff and Contractors on the google drive.
Space 2B You will look for opportunities to raise awareness of modern slavery and human rights abuses. Appropriate training and guidance will be provided. Training will include how to identify the risks of modern slavery and ensure that suspected instances are handled correctly.
Space 2B You will provide modern slavery information, advice and guidance to contractors, commissioners, organisations, and partnerships and where feasible will offer external training.
Space 2B You will maintain records of all staff and contractors who have completed modern slavery training.
Assurance and Transparency:
Space 2B You has committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place within services provided or in any supply chain.
Space 2B You takes a risk-based approach to its procurement, contract management and supply chain management processes in relation to modern slavery and keeps them under continuous review.
As part of ongoing risk assessment and due diligence processes, Space 2B You will consider whether circumstances warrant the auditing of contractors to demonstrate their compliance with this policy.
To supplement this policy, Space 2B You t will voluntarily publish an annual Transparency Statement for each financial year, which will include details of activities undertaken by Space 2B You and its supply chains to combat modern slavery. The Transparency Statement will be published on the Space 2B You website.
Non-Compliance, Reporting and Victim Support:
If any staff member or Contractor is discovered to have breached this policy, then appropriate action will be taken. This may include disciplinary proceedings and reporting concerns to the police.
If any commissioner, organisation, or partnership working with Space 2B You is found to have breached this policy, then appropriate action will be taken; this may range from considering the possibility of breaches being remediated, to terminating agreements and informing the authorities.
Individuals who have reasonable suspicion or evidence of non-compliance with the Act in connection with any member of Spaced 2B you are encouraged to report their concerns to the Directors:
Alternatively, if any member of Space 2B You holds information that could lead to the identification, discovery, and recovery of victims of modern slavery or human trafficking in the UK:
Contact the Modern Slavery Helpline on 080 0012 1700 (open 24 hours a day, 365 days a year)
Report it online to the Modern Slavery Helpline Modern Slavery Helpline
If you think you are a victim of modern slavery or human trafficking:
Contact the Modern Slavery Helpline on 080 0012 1700 or report it online.
Contact the Victim Support Helpline on 080 8168 9111
Visit the Victim Support website Supportline - Victim Support
Policy Review:
This policy will be reviewed on an annual basis, to establish whether Space 2B You’s approach continues to follow best practice by:
Assessing and interpreting any recent or emerging case law and best practice.
Benchmarking Space 2B You’s activities against statements and action plans undertaken by similar public and private organisations.
Re-evaluating the risk of non-compliance as part of our annual risk management and assurance processes.
Information Governance
Personal identifying Information for both clients and staff is confidential and must not be disclosed to unauthorised persons and will continue in perpetuity. This is a legal obligation; therefore, any breaches of personal confidential information or data may result in prosecution and/or an action for civil damages under the General Data Protection Regulations 2018.
Disciplinary Actions
Breach of this Code of Conduct may result in disciplinary action.
Contact Details
If staff members are concerned that there has been a breach of this Code of Conduct, they must inform Space 2B You directors Marie-Anne McKee and Alison Joyce.
Telephone:
020 3048 3331 (ext. 301)
Email:
barbara.johnston@space2byou.co.uk
marie-anne.mckee@space2byou.co.uk