1. Policy statement
Sage Signal Bureau Ltd (“SSB” or “the Company”) is committed to conducting its business ethically and responsibly and to preventing modern slavery and human trafficking within its operations and supply chain.
SSB has zero tolerance for slavery, forced labour, servitude, human trafficking or other forms of exploitation.
Although SSB is not currently required to publish an annual modern slavery statement under section 54 of the Modern Slavery Act 2015, the Company considers it appropriate to maintain proportionate controls and expectations in this area.
2. Scope
This policy applies to:
- directors;
- employees and workers;
- contractors and consultants;
- suppliers and service providers;
- recruitment agencies and other business partners; and
- anyone acting for or on behalf of SSB.
3. Our commitments
SSB will seek to:
- operate lawfully and ethically;
- treat workers fairly and with dignity;
- ensure workers are paid in accordance with applicable minimum-pay requirements;
- undertake appropriate Right to Work checks;
- remain alert to signs of forced labour or exploitation;
- consider modern-slavery risks when engaging suppliers or business partners;
- encourage concerns to be raised promptly; and
- take appropriate action where concerns are identified.
4. Worker protections
SSB will not knowingly participate in or support any arrangement involving:
- forced or compulsory labour;
- withholding identity documents without lawful reason;
- coercion, threats or intimidation;
- unlawful deductions or withholding of pay;
- debt bondage;
- human trafficking;
- exploitation of vulnerable individuals; or
- restriction of a worker’s freedom to leave employment in accordance with their contractual and legal rights.
5. Recruitment and onboarding
SSB will take reasonable steps to ensure that workers are recruited and onboarded transparently.
This includes:
- verifying identity and Right to Work where required;
- providing appropriate employment documentation;
- ensuring pay arrangements are explained clearly;
- operating payroll transparently; and
- remaining alert to circumstances suggesting that another person may be controlling or exploiting the worker.
6. Suppliers and business partners
SSB expects suppliers and business partners to comply with applicable modern-slavery and human-trafficking laws.
Where appropriate and proportionate to the risk, SSB may:
- request information regarding a supplier’s modern-slavery controls;
- consider relevant policies or due-diligence information;
- investigate credible concerns; and
- reconsider or terminate a relationship where serious concerns cannot be satisfactorily resolved.
7. Warning signs
Possible indicators of modern slavery or exploitation may include an individual:
- appearing to be controlled or intimidated by another person;
- being unable to speak freely for themselves;
- having limited control over their own identity documents;
- appearing fearful or reluctant to engage;
- being transported or housed in unusual or concerning circumstances;
- reporting unexplained deductions, debts or control over their wages;
- working excessive hours under apparent coercion; or
- otherwise showing signs that their freedom or employment choices may be restricted.
8. Raising concerns
Anyone who suspects modern slavery, human trafficking or exploitation connected with SSB’s business should report the concern promptly to:
[INSERT CONTACT / DIRECTOR]
Concerns may also be raised under SSB’s whistleblowing arrangements.
Individuals should not place themselves at risk or attempt to investigate suspected criminal conduct themselves.
Where appropriate, SSB may refer concerns to the relevant authorities or seek specialist advice.
9. Protection from retaliation
SSB will not tolerate retaliation against anyone who raises a genuine concern in good faith.
10. Training and awareness
SSB will provide appropriate information or guidance on modern-slavery risks where relevant to an individual’s role.
Particular awareness may be appropriate for anyone involved in onboarding workers, dealing with recruitment agencies, managing suppliers or handling worker concerns.
11. Breaches
A serious breach of this policy by an employee may result in disciplinary action.
SSB may terminate its relationship with a supplier, contractor or business partner where there is credible evidence of modern slavery, human trafficking or serious exploitation.
12. Review
This policy will be reviewed periodically and updated where necessary to reflect changes in legislation, business operations or identified risks.