Modern Slavery Policy and Procedure
Central Managed Services Ltd is committed to operating within the guidelines and legislation of the Modern Slavery Act 2015 and sets out the actions that Central Managed Services Ltd will take to understand potential modern slavery risks related to its business activities and supply chains.
Central Managed Services Ltd is committed to preventing modern slavery in its business activities and its supply chains and detailed below are actions that have been implemented, and will continue to be, with the aim of fulfilling this commitment.
Policy
We are committed to the prevention of modern slavery which includes servitude, forced labour, human trafficking and child slavery. Our Modern Slavery policy is delivered through a range of associated policies and procedures:
- Ethical Code of Conduct Policy
- Recruitment Policy
- Environmental Policy
- Corporate Responsibility Policy
The responsibility for monitoring of compliance including employee salary, employment rights and supply chain compliance is that of the Group Director and Compliance Manager.
Understanding the Risks of Modern Slavery The key direct risks of Modern Slavery to Central Managed Services Ltd are:
- No contracts of employment including zero hours contracts.
- Under pay of employees, self-employed contractors and subcontract companies – not paying as a minimum the living wage, and not paying an appropriate market rate for services engaged.
- Excessive working hours – Anyone who wishes to work more than 48 Hours a week must sign a working time regulation form.
- Not been entitled to work in the country of employment.
- Poor physical working conditions, including safety conditions.
- Bullying, discrimination and harassment.
Due Diligence
We shall ensure that:
- Individuals have the right to work in the country of employment.
- as a minimum a Living Wage is paid.
- that working hours restrictions are complied with, and excessive working hours discouraged.
- that bullying, discrimination and harassment is not permitted or tolerated in any form.
- that site conditions are safe and provide a working environment conducive to the protection of the environment, human health and quality workmanship.
All non-conformity shall be recorded and the required actions implemented in a timely manner. Policy Review This will be subject to review following any lessons learnt, identification of non-compliance and as a minimum annually.