Modern Slavery Act
Modern slavery is a crime and 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.
NHCC has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to 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.
NHCC is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
Scope/to whom this policy applies
We therefore expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for NHCC or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and NHCC may amend it at any time. This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with other workplace policies and procedures which can be found in the staff handbook or on in group’s intranet. Staff are encouraged to familiarise themselves with the policies.
NHCC Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations.
The Directors have primary responsibility for implementing this policy, but monitoring its use and effectiveness, on a day-to-day basis, with our clients, customers and contractors falls to all senior managers within the business, as well as dealing with any queries about it, 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.
Compliance with this policy
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. They are required to avoid any activity that might lead to, or suggest, a breach of this policy. They must notify their manager or the Directors as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future. They 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 they believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager or the Directors as soon as possible.
If they 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, they must raise it with their manager or the Directors. 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.
NHCC is 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.
Communication and awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, is provided as necessary. Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. NHCC may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.