The Modern Slavery Act (MSA) 2015 covers four activities:
Exercising powers of ownership over a person
The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour
Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Arranging or facilitating the travel of another person with a view to their exploitation
This policy covers all four activities.
Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it's not. At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense. The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
With this in mind, we need to pay particularly close attention to:
The Company, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.
We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
We recognise that our supply chain is our biggest risk area for exposure to modern slavery. We operate in a sector where our suppliers may make use of seasonal workers employed on a variety of types of contracts. We manage these risk areas through our procedures set out in this policy and elsewhere.
We make a clear annual statement that we take our responsibilities to our employees, people working within our supply chain and our clients seriously. We make this statement as part of our company reporting.
Modern slavery is a complex and multi-faceted crime and tackling it requires everyone to play a part. Bordeaux Index opposes modern slavery in all its forms. We are committed to preventing exploitation and human trafficking and to protecting our workforce through the implementation of effective systems for transparency in all our business dealings.
Bordeaux Index does not and will not knowingly support or deal with any business involved in slavery or human trafficking. Bordeaux Index expects all those in its supply chain to be opposed to slavery and human trafficking. We seek to ensure that we can account for each step of our supply processes—we know who is providing goods and services to us and we are in the process of implementing systems to:
If, through our recruitment process, we suspect someone is being exploited, our HR team will follow our reporting procedures (See Reporting Slavery).
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
However, the following key signs could indicate that someone may be a slavery or trafficking victim.
This list is not exhaustive.
Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person's circumstances which may indicate something is not quite right.
If you have a suspicion, report it.
Talking to someone about your concerns may stop someone else from being exploited or abused.
If you think that someone is in immediate danger, dial 999.
Otherwise, you should discuss your concerns with the COO who will decide a course of action and provide any further advice.
Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the COO before taking any further action.
We are working towards ensuring a higher level of understanding of the risks of modern slavery and human trafficking in our business.
We will review our Anti-slavery policy annually. We will provide information on any changes we make.
Approved by the Board of Directors of Bordeaux Index Limited and signed on their behalf by: