Ashfords LLP are committed to conducting its business in an honest and ethical manner. We will not tolerate the use of modern slavery and human trafficking anywhere within our organisation or in any of our supply chains. This policy sets out our approach to ensuring that we comply with our legal obligations and continue to protect our integrity and reputation.
This policy applies to all members, employees and consultants (permanent, temporary or fixed term), and must be observed. Failure to comply with this policy will be treated as gross misconduct and will be subject to the firm's disciplinary procedure.
Modern Slavery and Human Trafficking
Modern slavery is a crime resulting in despicable abuse of human rights. The Modern Slavery Act (MSA) 2015 came into force as from March 2015 and consolidates slavery and trafficking offenses. It covers four activities:
- Forced or compulsory labour
- Human trafficking
It ensures that offences are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002. The National Crime Agency, the police and other law enforcement agencies have the powers to bring to justice those engaged in human trafficking and slavery. Modern slavery is a complex and multi-faceted crime and tackling it requires all partners and staff of Ashfords LLP ("the Firm") to play a part. Protecting our workforce and reputation is vital. The MSA 2015 highlights the important need for businesses, and therefore the Firm, to play a part in tackling slavery.
Responsibilities and Commitments
The Firm, all employees and members have a responsibility to ensure all colleagues and Business Partners are safeguarded, treated fairly and with dignity.
The Firm will:
- maintain clear policies and procedures preventing exploitation and human trafficking, protecting our colleagues, Business Partners and our reputation;
- be clear about our recruitment ;
- check our supply chains (see Supply chains);
- make appropriate checks on all employees, recruitment agencies, suppliers, etc.;
- have in place an open and transparent grievance process for all staff.
- make a clear annual statement which will show a summary of the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of the business or our supply chains. It will be published on our website at the end of each financial year.
We are expected to build on our statement each year and therefore show that improvements can be made.
Supervisors and Line-Managers will:
- listen and be approachable to colleagues;
- respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;
- remain alert to indicators of slavery;
- raise awareness by discussing issues and providing training;
- use their experience and professional judgement to gauge situations.
- follow the reporting procedure (see Reporting) if there is any suspicion of a colleague or someone in our supply chain being controlled or forced by someone else to work or provide services;
- follow the reporting procedure if a colleague tells them something that may indicate they are or someone else is being exploited or ill-treated.
The principal areas of risk we face, related to slavery and human trafficking, include and which we need to pay particularly close attention to are, but are not limited to the following Business Partners.
Cleaning and catering suppliers
Recruitment through agencies
Breaches of money laundering and counter terrorist financing legislation
The Firm will manage these risks through identified procedures and controls as set out in this policy.
Supply chains (a supplier is any individual or company which provides goods or services)
We (the Firm) will thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
We will inform companies that we do business with that we are not prepared to accept any form of exploitation;
We will review our supplier contracts to ensure they will contain an anti-slavery clause which prohibits suppliers and their employees from engaging in slavery or human trafficking;
- Each step of the supply process will be accounted for. We will know who is providing goods and services to us, and we will have mechanisms and processes in place to check, including
- Risk assessing suppliers
- Auditing suppliers
- Identifying suppliers by total spend/goods or services/location
Recruitment using agencies
HR will follow the Firm's policy and only use agreed specified reputable recruitment agencies.
To ensure the potential for slavery and human trafficking is reduced as far as possible, we will thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
- Conducting background checks
- Investigating reputation
- Ensuring the staff an agency provides have the appropriate paperwork (e.g. work visas)
- Ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying
- A regular review of agents on our list.
- We always ensure that all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work
- We always ensure staff are legally able to work in the UK
- We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited)
- We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
If through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures.
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim. The person:
- may not be in possession of their own passport, identification or travel documents;
- will allow others to speak for them when spoken to directly;
- will be withdrawn or appear frightened;
- does not seem to be able to contact friends or family freely;
- has limited social interaction or contact with people outside their immediate environment
A person may display a number of the indicators as set out above but they may not necessarily be a victim of slavery or trafficking.
If you have any concerns, you should raise them with Risk and Compliance or the firm's HOLP, who will decide a course of action and provide any further advice. If you believe the victim may be in immediate danger, please dial 999. Please be aware though, that not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk.
It is therefore important that in the absence of an immediate danger, you should discuss your concerns first with R&C or the HOLP before taking any further action.
We provide training to those staff members who are involved in managing recruitment and our supply chains.
The Firm will monitor our procedures and review the Anti-Slavery policy regularly and at least annually on publication of the Firm's annual statement. We will provide information and (if necessary) training on any changes which are made.