)), 2.Power to stop, board, divert and detain, 9.Protection of constables and enforcement officers, 12.Power to stop, board, divert and detain, 13.Power to search and obtain information, 20.Power to stop, board, divert and detain, 21.Power to search and obtain information, 27.Protection of constables and enforcement officers, Public authorities under a duty to co-operate with the Commissioner, Offences to which defence in section 45 does not apply, 7.Offences against the Person Act 1861 (c. 100), 9.Infant Life (Preservation) Act 1929 (c. 34), 10.Children and Young Persons Act 1933 (c. 12), 11.Public Order Act 1936 (1 Edw. Meaning of exploitation 4. We are fully supportive of the Modern Slavery Act 2015 and its intention to tackle modern slavery in all its forms, including slavery, servitude, forced labour and trafficking. Within its sphere of influence, LVMH supports the values, freedoms and fundamental rights promoted in these texts. We use some essential cookies to make this website work. (1) Section 161A of the Criminal Justice Act 2003 (courts 26.Health and Social Care (Community Health and Standards) Act 2003 (c. 43), 27.Prevention of Social Housing Fraud Act 2013 (c. 3). Added information to highlight that future changes will made to what you need to do to report modern slavery risks in your supply chain. Modern Slavery Act 2015 Modern slavery and human trafficking statement. Some suppliers source in China and Thailand. This law requires all business entities that carry on a business, or part of a business, in any part of the United Kingdom to prepare and publish a slavery and human trafficking statement. Read Our 2021 Modern Slavery Act Statement. For a limited partnership, registered under the Limited Partnerships Act 1907, a general partner must sign the statement. This indicates the number of entities that are contained in every Suppliers corporate structure. This Statement is made on behalf of Royal Bank of Canada (the Bank) and a number of its subsidiaries (collectively RBC, we, us, or our) pursuant to section 54(1) of the U.K. Modern Slavery Act 2015 (the U.K. Act)1 and . this statement is made in accordance with section 54 of the modern slavery act 2015 (the act) as it applies to sophos limited, a commercial organisation that carries on business in the uk, supplying goods and services and having a total annual turnover of 36 million or more, and all entities in the sophos group global structure (together sophos, Details of this review and any actions undertaken will be published in the next Statement. Starting this month, the government will require all commercial organisations that operate in . For a limited liability partnership, a designated member must sign it. Further, Sophos compliance with the U.K. Modern Slavery Act is a comprehensive platform under which Sophos also meets the broader demands of similar legislation, such as theCalifornia Transparency in Supply Chain Act of 2010, certain U.S. federal regulations andThe Commonwealth Modern Slavery Act 2018. DAC Beachcroft is a leading international legal services business with more than 2,500 people across the UK, Europe, Asia-Pacific and Latin America. Dont worry we wont send you spam or share your email address with anyone. The law also creates the obligation to report on steps taken during . Products. This statement is in respect of GTIL's financial year ended 31 December 2021 and was . Dont include personal or financial information like your National Insurance number or credit card details. We use some essential cookies to make this website work. This questionnaire was adapted from the Social Responsibility Alliance (SRA) Slavery and Trafficking Risk Template (STRT). Our Policies 10. In July 2018, the home secretary commissioned an independent review of the act, to look at how effective it's been. The statement should detail the steps that your organisation is undertaking to ensure that your global supply chain is slavery free. requests suppliers to agree to improve and correct any deficiency discovered. In the meantime, you should continue to meet the current legal requirements for reporting set out on this page. Dependent on the legislation item being viewed this may include: Use this menu to access essential accompanying documents and information for this legislation item. Following the transparency in supply chains consultation, the government will. II. , which has been updated in 2017 following the update of the LVMH Suppliers Code of Conduct (2017), states that: The LVMH Group expects its Companies to establish and promote exemplary relations with all their partners, anchored in responsibility, fairness and integrity. Donations, legacies and grants, where the donor receives no service or benefit, are generally not considered to be derived from business activities so do not need to be included when deciding whether a charity meets the 36 million turnover threshold. 2021 Statement. Dont include personal or financial information like your National Insurance number or credit card details. Access essential accompanying documents and information for this legislation item from this tab. Where the organisation is a limited liability partnership (LLP) the statement must be approved by the members. Updated the link for 'Ethical Trading Initiative Modern Slavery Statement Evaluation Framework' under 'Reporting guidance' heading. in cases of high risk, we may request suppliers to provide a Statement of Compliance on their actions to prevent slavery and to confirm that any concerns have been satisfactorily and promptly resolved; We undertake detailed due diligence when onboarding new Distributors requesting that they have their own Policy regarding Modern Slavery or Human Trafficking, if this is not the case the Distributor is required to agree to comply with Sophos policy. We can account for each step of our supply processes and we know who is providing goods and services to us; Our level of communication and personal contact with the next link in our supply chain and their understanding of, and compliance with, our expectations. Slavery, servitude and forced or compulsory labour, Committing offence with intent to commit offence under section 2, Power to make slavery and trafficking reparation orders, Effect of slavery and trafficking reparation orders, Slavery and trafficking reparation orders: supplementary provision, Forfeiture of land vehicle, ship or aircraft, Detention of land vehicle, ship or aircraft, Slavery and trafficking prevention orders on sentencing, Slavery and trafficking prevention orders on application, Effect of slavery and trafficking prevention orders, Interim slavery and trafficking prevention orders, Effect of slavery and trafficking risk orders, Interim slavery and trafficking risk orders, Enforcement powers in relation to ships: England and Wales, Enforcement powers in relation to ships: Scotland, Enforcement powers in relation to ships: Northern Ireland, Hot pursuit of ships in United Kingdom waters, The Independent Anti-slavery Commissioner, Defence for slavery or trafficking victims who commit an offence, Special measures for witnesses in criminal proceedings, Guidance about identifying and supporting victims, Regulations about identifying and supporting victims, Duty to notify Secretary of State about suspected victims of slavery or human trafficking, Nationality, Immigration and Asylum Act 2002 (c. 41), Criminal Justice (Scotland) Act 2003 (asp 7), Asylum and Immigration (Treatment of Claimants, etc.) You will also be able to provide a summary of your statement by answering additional questions. Under section 54 of the Modern Slavery Act 2015, organisations that meet certain criteria are legally required to publish an annual modern slavery statement in a prominent place on their website. Sophos Statement covers the following topics: During the fiscal year ending 31 March 2021, the Group has focused on training, monitoring, and ongoing enforcement of the Groups systems and processes to maintain high standards and has continually improved Sophos ability to see, understand, and effectively manage the risk of modern slavery in any form. Other modern slavery act disclosure legislation also does not impose a monetary penalty for failing to prepare a statement . Added a link to the Coronavirus (COVID-19): reporting modern slavery for businesses guidance page. Halma plc (Halma) supports the provisions set out in the Modern Slavery Act 2015 (Act) and has taken steps to prevent modern slavery occurring in its supply chain and within its own operations. Preventing all forms of slavery in our business & supply chains. Anthology has a zero-tolerance approach to modern slavery. This is a requirement under section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015. If a group chooses to publish one statement, it: Some holding companies may not meet the criteria for publishing a statement, for example, because they do not provide goods or services. Section 54 (1) of the Modern Slavery Act 2015 states that corrective action must be implemented to eliminate practices associated with slavery and human trafficking within business. This statement is made pursuant to section 54 of the Modern Slavery Act 2015. Certain commercial organisations must publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains. Check benefits and financial support you can get, Limits on energy prices: Energy Price Guarantee, Demonstrate compliance with the minimum legal requirements, What to include in a modern slavery statement, Add your statement to the government registry, government modern slavery statement registry, future changes to the reporting requirements for modern slavery statements, transparency in supply chains consultation response, transparency in supply chains consultation, add your most recent statement to the registry, Read all of the required and optional questions to help you prepare your submission, Ethical Trading Initiatives Modern Slavery Statements Evaluation Framework, Ethical Trading Initiative Modern Slavery Statement Evaluation Framework, CORE Coalition Recommended Content for Modern Slavery Statement, CORE Coalition Examples of Weak and Notable Practice, CORE Coalition Beyond Compliance: Effective Reporting Under the Modern Slavery Act, Walk Free Foundations Business and Investor Toolkit, Ethical Trading Initiative Base Code Guidance: Modern Slavery, Ethical Trading Initiative Guide to Buying Responsibly, IHRB Implementing Responsible Recruitment, CORE Coalition Tackling Modern Slavery Through Human Rights Due Diligence, Interactive map for businesses of anti-human trafficking organisations, Stronger2gether Tackling Modern Slavery in UK Businesses Toolkit, Tackling modern slavery in supply chains: PPE case study e-learning course, modernslaverystatements@homeoffice.gov.uk, Procurement Policy Note 05/19: Tackling Modern Slavery in Government Supply Chains, Slavery and human trafficking in supply chains: guidance for businesses, Add your modern slavery statement to the statement registry, it is a body corporate or a partnership, wherever incorporated or formed, it carries on a business, or part of a business, in the UK, it has an annual turnover of 36 million or more, it provides service or support functions in the UK, it has other visible UK business presence, for example a website, must cover the steps taken to prevent modern slavery in all the organisations within that group that meet the criteria, and their supply chains, should clearly name the parent and subsidiary organisations it is covering, should be published on the UK websites of all the organisations covered by the statement, Policies in relation to slavery and human trafficking, Key performance indicators to measure effectiveness of steps being taken, Training on modern slavery and trafficking, acting transparently and disclosing information about any modern slavery risks you have identified and what actions you have taken in response to them, targeting your actions where they can have the most impact by prioritising your risks, making year-on-year progress to address those risks and improve outcomes for workers in your business and supply chains. Our Business 3. KPMG International Services Limited has issued its Modern Slavery Act Statement 2021, in accordance with the scope of section 54 of the Modern Slavery Act of 2015. This Statement sets out G&T's actions taken to comply with the Modern Slavery Act 2015 during the financial year ending 30 April 2021 and was approved by G&T's Management Board on 14 February 2022. However, any organisations within the holding companys corporate structure that do meet the criteria must publish a statement or be covered by a group statement. Assessment, Code of Conduct and Statement of Compliance. This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes Go City's slavery and human trafficking statement for the financial year ending 31 December 2020. , which has been updated in 2017, in which: LVMH expects exemplary behavior by its employees, fully respecting the Groups ethical commitments to act to the highest integrity standards, respect and engagement in their behavior and in the way they conduct business every day and everywhere. Dependent on the legislation item being viewed this may include: Click 'View More' or select 'More Resources' tab for additional information including: All content is available under the Open Government Licence v3.0 except where otherwise stated. This statement sets out the steps that Oversea-Chinese Banking Corporation Limited ("OCBC") and our owned and controlled subsidiaries have taken in relation to our responsibilities under both the UK Modern Slavery Act 2015 (the "UK Act") and the Australian Modern Slavery Act 2018 (Cth) (the "Australian Act") to mitigate the risk of modern slavery taking place in our . The following measures support this: Sophos makes responsible sourcing decisions, develops plans to avoid brand damage, and complies with regulatory demands within the below legislation: To ensure Sophos actions expressed in its Modern Slavery Statement met all requirements laid out the Act, the company participated in a peer review facilitated by a trade association within its industry segment.ii Feedback from the reviews support Sophos in meeting these requirements, as well as providing further information about Sophos actions that reduce and remove modern slavery in its supply chain. The turnover of the franchisee should not be used to calculate the franchisers turnover. are made available on a dedicated website accessible to all Mot Hennessy employees on an intranet. We ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work; We ensure staff are legally able to work in the country in which they are recruited; We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited); We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits to which they may be entitled; We invest in the professional development, health, and wellbeing of Sophos staff; We pay all Sophos employees in the UK at least the Living Wage (pro rata in the case of part-time employees; vacation students and interns are paid an allowance); If, through our recruitment process, we suspect someone is being exploited, our Human Resources Team will follow our reporting procedures; We conduct due diligence checks on any recruitment agency that we use to ensure that it is reputable and conducts appropriate checks on all staff that they may supply to us. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Verint UK's slavery and human trafficking statement for the financial year ending 31st January 2023. Macdonald & Muir has implemented various policies that are relevant to that goal and which sets out what is expected from its business, employees and external suppliers: The 2017 updated LVMH Code of conduct is available online: https://r.lvmh-static.com/uploads/2017/12/lvmh-code-of-conduct-2017_122017.pdf. This statement has been made and adopted by Intelsat Global Sales & Marketing Ltd. ("IGSM") pursuant to Section 54 of the Modern Slavery Act of 2015 (the "Act"). To strengthen compliance within our supply chain, Coforge has implemented anti-modern slavery requirements with all our new or renewed suppliers' agreements to acknowledge, represent and warrant that they effectively comply with the Modern Slavery Act 2015, including reporting any recognised Modern Slavery Act 2015 practices or issues. When deciding whether a charity meets the turnover criteria, you should include income received from business activities, such as the provision of goods and services for a fee. It sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK. In Schedule 11 to the Proceeds of Crime Act 2002 (1) Section 161A of the Criminal Justice Act 2003 (courts Health and Social Care (Community Health and Standards) Act 2003 (c. 43), Prevention of Social Housing Fraud Act 2013 (c. 3), the original print PDF of the as enacted version that was used for the print copy, lists of changes made by and/or affecting this legislation item, confers power and blanket amendment details, links to related legislation and further information resources. The Home Offices statutory guidance provides more detailed advice for organisations on complying with section 54 of the Modern Slavery Act 2015. Indicators used to evaluate risk, include managing the risks in our own business. To demonstrate that you have met this legal requirement, your statement should clearly state that board approval has been given with the date of approval. This statement is published on behalf of Fuller, Smith & Turner P.L.C. Modern Slavery Act 2015 Transparency Statement G&T provides a wide range of professional construction consultancy and related professional services. 1994/570), 27.Protection from Harassment Act 1997 (c. 40), 30.International Criminal Court Act 2001 (c. 17), 31.Anti-terrorism, Crime and Security Act 2001 (c. 24), 32.Female Genital Mutilation Act 2003 (c. 31), 34.Domestic Violence, Crime and Victims Act 2004 (c. 28), 1.Children and Young Persons Act 1933 (c. 12), 3.Police and Criminal Evidence Act 1984 (c. 60), 4.Sexual Offences (Amendment) Act 1992 (c. 34), 6.Asylum and Immigration (Treatment of Claimants, etc.) Number/percentage of new and existing suppliers satisfactorily screened using risk assessment tools and/or self-assessment questionnaires, including risk scoring and categorization; Number/percentage of suppliers who have signed our Code of Conduct; Number/percentage of suppliers who have provided a satisfactory Statement of Compliance on their actions to prevent slavery, when so requested, and any concerns have been satisfactorily and promptly resolved. Group Structure You may wish to seek legal advice to decide if your organisation needs to produce an annual statement. Introduction. The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015has set the minimum turnover threshold at 36 million. Our Social Impact and Human Capital policy 5. For more information see the EUR-Lex public statement on re-use. To help you determine if you need to do this, consider whether the following applies to your organisation this is not an exhaustive list: Some large corporate groups may have more than one subsidiary organisation which meets the criteria for publishing an annual statement. 8 & 1 Geo. We consider that the principal areas in which Sophos faces risks related to slavery include: The formal process for identifying, evaluating, and managing significant risks faced by the Group is overseen by the Board, along with the Companys Finance, Legal, and Compliance Teams. It sets out how we, during the financial year ending 28 February 2021, continued our efforts to ensure that no slavery or human trafficking takes place in our supply chain or any other part of our business. All those subject to the Policy are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains or those of any current or potential Suppliers, at the earliest possible stage. The government has announced future changes to the reporting requirements for modern slavery statements. Added a link to the process for submitting a government modern slavery statement. On December 13, 2018, John McKay, a Member of Parliament, introduced a private member's Bill proposing a Canadian modern slavery act (the "Canadian MSA"). These questions are optional, however you are encouraged to answer all questions as fully as possible, to help improve understanding of modern slavery risks and best practice. In the context of the provision of the UK Modern Slavery Act 2015, The Australian Modern Slavery Act 2018 and the California Transparency in Supply Chains Act, 2012 , DSM explains in this statement our efforts to identify, assess and manage the risks of modern slavery and human . Macdonald & Muirs aim is to eliminate risk of Modern Slavery in its business operations and its supply chains. It sets out Aydya's efforts towards . Consistent with the Companys Whistleblowing Policy, the Sophos Group is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion. Our Suppliers: we take the following actions for each Supplier: Our Business: we take the following actions within our company: Mandatory training in relation to Modern Slavery, Conflict Minerals, and Whistleblowing is provided to all existing Group employees and new joiners alike and is re-taken on an annual basis. At present, it remains to be seen whether the Bill will gain traction and, if it does, what the final Canadian MSA will look like. It requires them to publish a transparency statement annually, within six months of the end of the organisation's financial year. It constitutes The Salvation Army International Headquarters' (IHQ) Modern Slavery Act 2015 Compliance Statement for the financial year ended March 2021. Group (together "Fuller's") pursuant to section 54 (1) of the Modern Slavery Act 2015 (the "Act"). If so, publish a modern slavery statement. To meet and demonstrate you have met the minimum legal requirements: Each year, assess whether your organisation meets the criteria for the preceding financial year. The Statement has been signed by Kris Hagerman, Chief Executive Officer, on behalf of Sophos Group Companies and published on the homepage of the company website atwww.sophos.com. This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and sets out the steps the Company has taken during the financial year from 1 August 2020 to 31 July 2021 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. Act 2004 (c. 19), 6.Criminal Justice and Licensing (Scotland) Act 2010 (asp 13), 8.Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015 (c. 2 (N.I. Investment trusts must publish an annual statement if they meet the criteria. This statement is made by Trainline in accordance with the requirements under section 54 of the Modern Slavery Act 2015 (the "Act"). slavery or human trafficking in our supply chains we intend to continue to monitor and build upon the processes we have already established. This is a new measure and has increased conversations regarding the subject of bonded labour and employee welfare; Suppliers are required to complete the Conflict Minerals Reporting Template (CMRT) a standardised reporting template developed by the Responsible Minerals Initiative (RMI); Suppliers have been asked to provide ISO 9001 and OHSAS18001 certification to evidence action they have undertaken in this matter; We ensure that we can account for each step of our hardware manufacturing processes and we know who is providing the hardware to us that we resell. Dry Goods from suppliers located in the following countries: UK, France, Portugal, Netherlands, Poland, Italy. It is good practice to keep previous statements on your website so that your progress can be monitored. Third party suppliers as well as their subcontractors and their own suppliers must comply with the Suppliers Code of Conduct and abide by the principles stipulated in the Convention of the International Labor Organization, the Universal Declaration on Human Rights, the UN Global compact, the OECD guidelines for multinational enterprises and the UN womens empowerment principles. Number/percentage of relevant staff trained, informed, or completed mandatory training. The Inchcape Shipping Services Group ("Inchcape") strongly supports the MSA. Occasionally, grant income might be seen to be derived from business activities. In line with the requirements of the Modern Slavery Act 2015 (the "Act"), this statement outlines the steps Aviva plc ('The Group' or 'We') has taken during the financial year ending 31 December 2021 to prevent any form of modern slavery from occurring within our business operations and supply chain. requires that supplier shall keep proper records to prove compliance with the suppliers code of conduct and provide access to complete, original and accurate records. If your organisation is required to produce a statement, it will be mandatory for you to add it to the registry in the future as part of the proposed changes to strengthen section 54 of the Modern Slavery Act 2015. The requirements apply to these companies' own operations and their supply chains. Any risks identified in the bottom-up approach deemed to be rated as higher risk are escalated in line with pre-defined escalation procedures for further evaluation. 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