Modern Slavery and Ethical Employment Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, human trafficking, and forced/compulsory labour, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. BCC IT has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all business dealings.

BCC IT is aware of the scope and structures of the Modern Slavery Act 2015 and recognises the negative impact on the industry and wider society of slavery and counterfeiting within the supply chain.

We will ensure, as far as possible, that no slavery or forced labour is used in any part of our supply chain by seeking written confirmation from our suppliers and asking them to send us copies of their implemented policies concerning Modern Slavery legislation. Thus underpinning our commitment to the Welsh Government’s code of practice on ‘Ethical Employment in Supply Chains’. As far as we can, we aim for a relationship of transactional transparency within our supply chain to ensure compliance with current legislation.

We request copies of supplier policies whilst conducting our due diligence for new suppliers, which are regularly reviewed to ensure, as far as possible, that none of our associates or suppliers have been involved with modern slavery or counterfeiting practices.

We have appointed a designated staff member to take overall responsibility for these actions, especially procurement processes and supply contracts. They are also responsible for cascading information and data to all senior managers to ensure that staff are kept informed of any developments or legislative changes, and to ensure that all documentation is kept up to date.

 

BCC IT adheres to the ETI (Ethical Trading Initiative) base code and ILO (International Labour Organisation) guidelines on best practices, which include.

  1. Employment is freely chosen.
    • No forced, bonded, or involuntary prison labour.
  2. Freedom of association and the right to collective bargaining are respected.
    • Workers have the right to join trade unions, labour associations, etc.
  3. Working conditions are safe and hygienic.
    • Companies comply with Health and Safety regulations.
  4. Child labour shall not be used.
    • The ILO has strict policies on this, which we are aware of and seek to comply with.
  5. Living wages are paid.
    • Wages within supplier organisations are benchmarked to a national standard.
  6. Working hours are not excessive.
  7. No discrimination is practised.
  8. Regular employment is provided.
  9. No harsh or inhumane treatment is allowed.
    • No employee within supplier companies is to be subjected to compulsion to work, physical or mental abuse.

 

We take our corporate social responsibility extremely seriously and are committed to ethical trading practices.

Concerning counterfeiting, we make every effort to ensure that our stock is sourced from reputable suppliers and that we have an audit trail showing the history and origins of the goods we source and sell. All stock is checked to appropriate quality and safety standards, and we also ensure that our suppliers are appropriate trade associations subscribing to approved British/ European standards.

BCC IT will not tolerate modern slavery or human trafficking in our organisation or our supply chains.

Our modern slavery policy covers the 12 commitments of the Welsh Government’s Code of Practice on Ethical Employment in Supply Chains.

Commitment 1

We have developed a written policy on ethical employment within our organisation and supply chains. We have communicated the policy throughout our organisation, and we will review it annually and monitor its effectiveness. As part of this, we have appointed the compliance team as part of the Anti-Slavery and Ethical Employment Champions.

Commitment 2

We have developed a policy on whistleblowing to empower staff to raise suspicions of unlawful and unethical employment practices, and which places a responsibility on staff to report criminal activity taking place within our organisation and our supply chains. This has been communicated throughout our organisation. We will review the policy annually and monitor its effectiveness. We will also provide a mechanism for people outside our organisation to raise suspicions of unlawful and unethical employment practices.

Commitment 3

Ensure that those involved in buying/procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices, and keep a record of those who have been trained.

Commitment 4

Ensure that employment practices are considered as part of the procurement process. We will:

  • Include a copy of our Policy on ethical employment (Commitment 1) in all procurement documentation.
  • Include appropriate questions on ethical employment in tenders and assess the responses provided.
  • Incorporate, where appropriate, elements of the Code as conditions of contract.
  • Ask our suppliers to explain the impact that low costs may have on their workers each time an abnormally low quote or tender is received.

Commitment 5

Ensure that the way in which we collaborate with our suppliers does not contribute to the use of illegal or unethical employment practices within the supply chain. We will:

  • Ensure that undue cost and time pressures are not applied to any of our suppliers if this is likely to result in unethical treatment of workers.
  • Ensure that our suppliers are paid on time following receipt of a valid invoice.
  • Ask our suppliers to explain the impact that low costs may have on their workers each time an abnormally low quote or tender is received.

Commitment 6

Expect our suppliers to sign up to an Ethical Employment Policy to help ensure that ethical employment practices are conducted throughout the supply chain.

Commitment 7

Assess our expenditure to identify and address potential issues of modern slavery, human rights abuses, and unethical employment practices. We will:

  • Conduct regular reviews of expenditure and undertake a risk assessment on the findings, to identify products and/or services where there is a risk of modern slavery and/or illegal or unethical employment practices within the UK and overseas.
  • Investigate any supplier identified as high risk by direct engagement with workers wherever possible.
  • Collaborate with our suppliers to rectify any issues of illegal or unethical employment practices.
  • Monitor the employment practices of our high-risk suppliers, making this standard agenda item for all contract management meetings/reviews.

Commitment 8

Ensure that false self-employment is not undertaken and that umbrella schemes and zero hours contracts are not used unfairly or as a means to:

  • Avoid, or facilitate avoidance of, the payment of tax, National Insurance contributions and the relevant minimum wages.
  • Unduly disadvantage workers in terms of pay and employment rights, job security and career opportunities.
  • Avoid Health and Safety responsibilities.

Commitment 9

Ensure that workers are free to join a Trade Union or collective agreement and to undertake any related activity and raise worker concerns without risk of discrimination. We will:

  • Not make use of blacklists / prohibited lists.
  • Ensure that our suppliers do not make use of blacklists / prohibited lists.
  • Not contract with any supplier that has made use of a blacklist / prohibited list and failed to take steps to put matters right.

Commitment 10

All our staff are paid in line with the Living Wage Foundation Living Wage as a minimum, and we encourage our suppliers to do the same.

We will:

  • Consider becoming an accredited Living Wage Employer.

Also, encourage our suppliers based overseas to pay a fair wage to all staff, and to ensure that staff working in the UK are paid at least the minimum wage.

Commitment 11

Produce an annual written statement outlining the steps taken during the financial year, and plans for future actions, to ensure that slavery and human trafficking are not taking place in any part of our organisation and its supply chains. We will:

  • Ensure that the statement is signed off at the senior management level.
  • Publish the statement on our website. If this is not possible, we will provide a copy to anyone within 30 days of a request being made.

Commitment 12

Should we use an outsourced contract we will ensure they are treated fairly and equally.

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Consistent with our risk-based approach, we may require.

  • As part of our ongoing risk assessment and due diligence processes with new suppliers, we will consider whether circumstances warrant us to conduct audits of suppliers for their compliance with our policy.
  • All suppliers must hold accurate records of the ages and working hours of all employees, who in all cases must not be less than the legal minimum age.
  • All wages must meet or exceed legal minimum levels, and any deductions must be reasonable, agreed and understood by the employees.

 

The organisation’s director has approved this statement.