The Modern Slavery Act came into force on 26 March 2015.
An Act to make provision about slavery, servitude and forced or compulsory labour and about human trafficking, including provision for the protection of victims; to make provision for an Independent Anti-slavery Commissioner; and for connected purposes.
These regulations require commercial organisations with a total turnover of at least £36 million to publish a slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015 (“the 2015 Act”).
Deeley Group Limited is fully committed to driving out the possibility of Slavery and Human Trafficking taking place in any of its Construction and Development activities undertaken by ourselves and our supply chain across the United Kingdom.
We have provided 7 principles to consider, namely:
Principle 1 – Proportionate procedures
The Deeley Group Employee Handbook – Section Two Contractual Conditions sets out the Rules of Conduct we expect from all staff and directors. In relation to The Modern Slavery Act 2015 we detail below our procedures:
Principle 2 – Understanding the indicators of forced labour
Forced labour is a form of modern slavery, and one of the worst forms of human exploitation in supply chains. It can also be incredibly difficult to identify and find evidence for. To learn more about the indicators of forced labour and why organisations use them to understand forced labour risks we use Sedex, one of the world’s leading ethical trade membership for guidance. They list the following indicators of forced labour:
More information on these indicators can be found at: https://www.sedex.com/understanding-the-indicators-of-forced-labour/
Principle 3 – Top Level Commitment
The Directors of Deeley Group Limited are totally committed to preventing slavery and human trafficking by persons associated with it and we will continue to foster a culture in which slavery or human trafficking is never acceptable.
The Employee Handbook and the above procedure clearly set out how we wish to deal with Modern Slavery Act 2015. Contravention of the Rules of Conduct may be treated as misconduct and dealt with through the disciplinary procedures. You should consult a Director about any circumstances which you believe could be regarded as inconsistent with our procedures.
Principle 4 – Risk Assessment
The Directors of Deeley Group Limited will take into account the extent of the organisation’s exposure to potential and external risks slavery and human trafficking on its behalf by people associated with it. This assessment will be reviewed and discussed at Deeley Group Board Meetings every six months or as deemed appropriate to assess any changes to markets etc and will be both informed and documented.
Principle 5 – Due Diligence in the Supply Chain
Due diligence procedure (via a proportionate and risk based approach) will be applied in respect of persons who do or will perform services for or on behalf of Deeley Group Limited, so as to mitigate slavery and human trafficking. We will apply the following procedures:
Principle 6 – Communication
By virtue of this memorandum and the Employee Handbook, we have communicated our policies and procedures to our directors and staff. Any changes in policy and procedures will be documented in a similar manner.
In July 2021 our front line staff (site and contract managers) and procurement team (surveyors and accountants) who liaise regularly with the supply chain undertook ‘Preventing Illegal Working’ awareness training.
Principle 7 – Monitoring and Review
The Directors of Deeley Group Limited, will every six months monitor and review the above procedures and any improvements and changes will be made where necessary.
Deeley Group Limited prides itself on its integrity and we know that we have a team working for us that uphold the highest standards and we do not deem it necessary to have too detailed or extensive specific extra procedures. In order to ensure compliance with the law and as Deeley Group Limited agrees with the principles of the legislation, the aforementioned policies and procedures are deemed appropriate to implement going forward.
Any queries regarding our commitment to the Modern Slavery Act in the last financial year should be directed to email@example.com.
Peter Hartill, Chairman, Deeley Group
Date 1 January 2022
Link to act – HR33 – Modern Slavery Act 2015 (signed copy available upon request)