1. Background
1.1 The Modern Slavery Act 2015 stems from a report published by the Centre for Social Justice in 2013 which highlighted the existence of modern slavery in the UK and asking that organisations make public the efforts made to develop transparent supply chains and recognise responsibilities in eradicating this crime.
1.2 J2 Research (“the Company”) has a responsibility to be alert to the risks, however small, in its activities and in the wider supply chain. As part of the safeguarding responsibilities the Company must recognise the potential impact of slavery; report concerns and take action as required.
2. Policies on Anti-Slavery and Human Trafficking
2.1 The Company is committed to ensuring that there is no modern slavery or human trafficking in supply chains or in any activities. This statement reflects the commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chain. This is clear within the procurement policies.
2.2 The Company takes its responsibilities for safeguarding very seriously and the safeguarding policy provides a framework to ensure that employees are kept safe at the Company and also that disclosures of abuse or potential abuse occurring at home or elsewhere are reported appropriately. This includes slavery and human trafficking.
3. Principal Risks
The key risks to the Company might be:
• Failure to fulfil its statutory and moral responsibilities in the safeguarding of employees which includes modern slavery, human trafficking and violation of human rights.
• Trading with a contractor or sub-contractor using slavery/forced labour including human trafficking or child labour and/or where workplace conditions such as working hours and health and safety are inadequate. This is an increased risk where the supply chain is multi-layered and/or in sourcing goods and services from parts of the developing world.
• Not having clear and well-communicated policies and procedures for concerns to be raised and addressed.
• Failure to train key staff and raise awareness throughout the Company.
4. Due Diligence Processes
As part of the initiatives to identify and mitigate risk, the Company has implemented the following:
• Clear policies for procurement and safeguarding;
• Without compromising value for money, wherever possible the Company builds professional relationships with local suppliers and always makes clear the expectations of business behaviour;
• With national or international supply chains the point contact should, wherever possible, be with a UK or European company or branch;
• Systems to encourage the reporting of concerns and the protection of whistleblowers are in place. Concerns regarding the supply chain and/or procurement practices should be made to the Managing Director. Safeguarding concerns should be made in accordance with Company policy.
5. Contractors’ Adherence to Company Values
The Company has zero tolerance to modern slavery and human trafficking. It is expected that all those in the supply chain and contractors comply with the Company’s values.
6. Training
To ensure a high level of understanding of the risk of modern slavery and human trafficking in supply chains and in activities, the Company provides training to relevant members of staff and raises awareness with its employees through the induction process.
7. Effectiveness in Combating Slavery and Human Trafficking
The Company uses the following indicators and actions to demonstrate how its ensures that slavery and human trafficking is not taking place in any part of the business or supply chains:
• additional checks conducted when procuring goods and services outside the UK or European Economic Area;
• all relevant staff trained;
• policies reviewed regularly;
• employees are aware of how to report a concern;
• awareness raising as part of the induction process.
