This statement sets out Conviction’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2020 to 31 March 2021.
In previous years, Conviction has published its statement no later than 30 June. We recognise that we are publishing this statement later than expected. This is because of reduced staff capacity and increased difficulty in gathering the required information from our suppliers during the coronavirus pandemic.
As part of the charitable sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.
Conviction is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Responsibility for our anti-slavery initiatives is as follows:
- Policies: Shirley McNaught is responsible for putting in place and reviewing policies and the process by which they were developed.
- Risk assessments: Conviction and all members of it’s community take a broad organisational responsibility for human rights and modern slavery risk analysis.
- Investigations/due diligence: Our CEO, Ryan Jarvis is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy We encourage all our workers, service users and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
- Employee code of conduct Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier/Procurement code of conduct We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency workers policy We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
Conviction undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:
- evaluating the modern slavery and human trafficking risks of each new supplier;
- conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular endorsing the “Stronger together” initiative;
- using databases, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular;
We have reviewed our key performance indicators (KPIs). As a result, we are:
- requiring all staff involved in the recruitment, selection and management of volunteers and/or financial or other procurement tasks to have completed training on modern slavery;
We require all staff involved in the recruitment, selection and management of volunteers and/or financial or other procurement tasks within our organisation to complete training on modern slavery as a module within our wider human rights and ethics training programme.
Our modern slavery training covers:
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation;
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.
As well as training staff, we have raised awareness of modern slavery issues by having a dedicated section to this important area on our intranet.
The section explains to staff:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
- what external help is available, for example through the Modern Slavery Helpline.