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Modern Slavery Policy
Statement and Purpose of Policy
The London Ethical Cleaning Company Limited (the Employer, we, our or us) has a zero tolerance approach to modern slavery, and are committed to acting ethically and with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains and that our operations do not contribute to the exploitation of vulnerable individuals.
Modern slavery is a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
This policy sets out the Employer’s and the Employees’ responsibilities in connection to ensuring that all persons working for us or on our behalf in any capacity, operate to the same ethical standards as we do, consistent with our disclosure obligations under the Modern Slavery Act 2015.
The Employer may amend this policy at any time, at our absolute discretion.
Responsibility for the Policy
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any relevant queries, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
The Employees’ Responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager or a company director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company director or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company director.
The Employer’s Responsibilities
The Employer’s responsibilities include:
Conducting risk assessments of our suppliers and subcontractors to identify any potential risks of modern slavery.
Conducting due diligence on new suppliers and subcontractors to ensure that they meet our ethical standards.
Monitoring and reviewing our existing suppliers and subcontractors to ensure ongoing compliance with our ethical standards.
Providing training and support to our employees, suppliers and subcontractors on modern slavery and ethical business practices.
We also require all of our suppliers and subcontractors to sign our Supplier Code of Conduct, which sets out our expectations in relation to ethical business practices.
Training and Awareness
We provide regular training to our employees, suppliers and subcontractors on modern slavery and ethical business practices. Where appropriate, this will include;
Raising awareness of the signs of modern slavery and how to report any concerns.
Providing guidance on our Supplier Code of Conduct and our expectations in relation to ethical business practices.
Ensuring that all employees, suppliers and subcontractors understand their responsibilities in relation to preventing modern slavery.
Reporting and Response
We encourage all employees, suppliers and subcontractors to report any concerns related to modern slavery. We have implemented a Whistleblowing Policy to ensure that any concerns raised are taken seriously and investigated thoroughly.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.
Breaches of this Policy
If we identify any instances of modern slavery within our business or supply chains, we will take immediate action to address the situation. This may include terminating relationships with suppliers or subcontractors who are not meeting our ethical standards, and reporting any illegal activities to the relevant authorities.
Review and Further Information
This policy and the practices and procedures that it outlines will be regularly reviewed by the Employer.
Employees should raise any concerns they have about the practices and procedures that this policy outlines with their managers and/or company director. This includes requesting new risk assessments be carried out or that further risk management steps be implemented.
Employees can obtain access to a copy of any of the other employment policies referred to within this modern slavery policy by contacting their manager.