1. Background – Why do we need a policy?
1.1. Modern slavery is a crime and 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. Camphill Village Trust, known as The Trust, has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or in any of its supply chains.
2. Purpose and Scope – What is the aim/who is it for?
2.1. The Trust is committed to ensuring there is transparency in its own business and in the approach to tackling modern slavery throughout its supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. The Trust expects the same high standards from all its contractors, suppliers and other business partners, and as part of contracting processes, includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. It expects that its suppliers will hold their own suppliers to the same high standards.
2.2. This policy applies to all persons working for the Trust or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractor, external consultants, third-party representatives and business partners.
2.3. This policy does not form part of any employee’s contract of employment and The Trust may amend it at any time.
3. Responsibility for the policy
3.1. The Trust’s Management Team have overall responsibility for ensuring this policy complies with the Trust’s legal and ethical obligations, and that all those under the Trust’s control comply with it.
3.2. The Trust have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
3.3. 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.
4. Compliance with the policy
4.1. All employees must read, understand and comply with this policy.
4.2. The prevention, detection and reporting of modern slavery in any part of the Trust business or supply chains is the responsibility of all those working for the Trust or under its control. Employees are required to avoid any activity that might lead to, or suggest a breach of this policy.
4.3. Employees must notify their manager or the company secretary in a whistleblowing capacity as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. Please refer to the Trust’s Whistleblowing policy.
4.4. Employees are encouraged to raise concerns about an issue or suspicion of modern slavery in any parts of the business or supply chains of any supplier tier at the earliest possible stage.
4.5. Employees should note that where appropriate, and with the welfare and safety of local workers as a priority, the Trust will give support and guidance to its suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
4.6.If an employee is unsure about whether a particular act, and the treatment of workers more general, or their working conditions within any tier of the Trust’s supply chains constitutes any of the various forms of modern slavery, they should raise it with their manager or through the company secretary in a whistleblowing capacity. Please refer to the Trust’s Whistleblowing policy.
4.7. The Trust 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 Trust 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. If an employee believes that they have suffered any such treatment, they should report this immediately to their manager or the company secretary in a whistleblowing capacity. Please refer to the Trust’s Whistleblowing policy.
5. Communication and awareness of this policy
5.1. The Trust has a zero-tolerance approach to modern slavery that must be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.
6. Breaches of this Policy
6.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Please refer to the Trust’s Disciplinary policy.
6.2. The Trust may terminate its relationship with other individuals and organisation’s working on our behalf if they breach this policy.
Review of this policy
This policy is expected to be reviewed within three years unless legislative change dictates otherwise. If change is deemed unnecessary, the policy will remain in force until such time as it is reviewed.
