1 9 Modern Slavery and Human Trafficking Statement 201 Introduction 1. This statement sets out Working Links’ actions to understand all potential modern slavery risks related to its business and to ensure steps are maintained to prevent slavery and human trafficking. This statement . relates to actions and activities during the year ending 31 December 201 calendar 9 tolerance approach to modern slavery and human trafficking and are fully - Working Links’ have a zero committed to preventing slavery and human trafficking in its corporate activities and ensuring there is transparenc y across the business and supply chains. As part of our initiative to identify and mitigate risk (including in relation to that of human trafficking and Act which serve to address the requirements of the Modern Slavery slavery) we operate a range of policies 2015. 2. Our policies Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective due diligence and contractual compliance. These include: Code of Conduct Our code makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply c hain. Whistle blowing Policy and business partners to report any , customers Working Links encourages all its workers, service users concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblo wing procedure is designed to make it easy for workers to make disclosures, without fear of service users, customers or others who have concerns can use our confidential retaliation. Employees, helpline. Recruitment Policy We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. Safeguarding Policy ve Our Safeguarding policy sets out the legislative requirements to provide a duty of care , promote positi being and provide a clear process for escalating concerns to protect the welfare of individuals. well - Equality, Diversity and Inclusion Policy Diversity and Inclusion Our Equality policy is in place to ensure that we treat people fairly and with resp ect. , Working Links is committed to being an Employer of Choice and we will strive to create and implement our . Equality, Diversity and Inclusion strategy 3. Our supply chains and supplier adherence to our values conduct and probity throughout our supply chain, requiring all of our We expect the highest standards of people to act with integrity and honesty. Our procurement processes include standard enquiries about ality assurance modern slavery and trafficking and we examine our supply chain using our dedicated qu functions including audit, supply chain management, legal and risk.
2 Working Links will continue to work with suppliers to ensure that they meet these standards and comply with the requirements of the Modern Slavery Act . 4. What we do s part of our commitment to preventing modern slavery and human trafficking we: A , ntroduce d 1. I which w as made compulsory in online training on the Modern Slavery Act to complete training on the act, d 2017/2018 ; A ll Working Links employees are require including how to identify and escalate any concerns. 2. Continue to review and develop the policies, processes and controls in place to support our commitment to mitigate risks of modern slavery across our organisation . Will develop and update this statement 3. annually to meet the requirements of the Modern Slavery Act. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 201 9 . Approval 5. Chief HR Officer, who will review and update it annually. This statement has been approved by the Document control This statement will be review ed at least annually to respond to any changes . Please refer to the Working Links website for the latest version. by Human Resources This statement is owned . Date Change d Version Author / Editor Approved by etails June 1.0 22 201 7 Statement introduced Chris Baker Clare Davey Clare Davey 1.1 8 November 2018 Statement reviewed Michelle Cairns