1. Application and Background
This policy applies to Quality Heating Services Ltd located in the United Kingdom (collectively the "Company" and its operations in the United Kingdom) and to all persons who work for or on behalf of the Company in respect of such operations.
This policy reflects the Company’s obligations under the Modern Slavery Act 2015 and the Company’s commitment more generally to avoid any form of modern slavery or human trafficking within its operations or its supply chain. The Company has a longstanding commitment to conducting business in a responsible way and in accordance with its Code of Conduct.
2. What is Modern Slavery?
Modern slavery includes:
- Slavery — the behaviour on the part of the offender as if they owned the victim, depriving the victim of their freedom;
- Forced or compulsory labour — work or service of a victim which involves coercion, either direct threats or violence or more subtle forms of compulsion. Work or service is extracted from the victim under the menace of any penalty and for which the victim has not offered themselves voluntarily; and
- Human trafficking — arrangements for the travel of the victim with a view to them being exploited.
It is important to recognise that modern slavery is prevalent throughout the world and whilst less common, exists in the United Kingdom and other developed countries.
3. Response to Modern Slavery
The Company will not tolerate any form of modern slavery within its own operations or within its supply chains. You should notify your line manager or compliance officer as soon as possible if you have any concerns, issues or suspicions about modern slavery in any parts of the business or its supply chains.
The processes in relation to the Company’s suppliers are set out below
The Company aims 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. The Company is committed to ensuring that 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 the Company’s business or its supply chains.
Modern Slavery and the QHS Supply Chain
The Company deploys processes to assess and validate its vendors prior to making either a purchase from or a payment to a vendor. These checks are required of all vendors before the vendor can be added to the Company's systems to allow payment to the vendor.
To augment this, the Company's standard purchase terms and conditions and other vendor agreements contain a specific requirement for its suppliers to comply with modern slavery legislation.
On an annual basis, QHS will issue a Modern Slavery Supplier questionnaire to selected suppliers. The selection of the suppliers is risk focused and, where selected, requires suppliers to report on what steps they are taking regarding the risk of modern slavery within their own supply chain which will allow the company to better assess potential risks of modern slavery in its supply chain.
The Modern Slavery Supplier Questionnaire
Suppliers targeted for receiving the questionnaire have been assessed annually on the basis of their exposure to potential risk with regards to compliance with the Modern Slavery Act (2015).
Criteria for this risk potential will include, as a minimum:
- Annual Spend with the vendor;
- Category(ies) of spend that the vendor provides to the Company; and
- Country of operation of business.
- Non-Conforming Suppliers
QHS Support Services undertake the assessment of questionnaires and liaise with the Compliance Officer to evaluate risk, consider further requests for information and determine appropriate action. Our HR Advisor will be involved in any case where there is considered to be a significant risk of modern slavery involving a supplier.
Additional steps for suppliers
All Company staff interacting with a supplier should remain vigilant as to any potential indictors of modern slavery, including in any visits to suppliers, and report these as appropriate. Where suppliers are considered to be at a higher potential risk for modern slavery it may be appropriate for staff to raise this with their line manager so that consideration can be given to whether any further specific steps for monitoring risks are appropriate.
5. Information and Training
This policy has been distributed and communicated to all Company staff and all staff are expected to read this policy closely. In addition, the Company has arranged training for those staff most likely to interact with suppliers with a potentially higher risk of modern slavery.
6. Responsibility for This Policy
The board of directors are accountable for this policy with responsibility for execution residing with the Compliance Officer who will monitor the implementation of this policy, deal with any queries about it and assess its effectiveness.