Compliance with modern slavery, human rights and ethical trading policy

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Scope

This procedure applies to all employees, contractors, suppliers, and other stakeholders associated with Safetynet Solutions Ltd.

Responsibilities

• Compliance Officer: Responsible for overseeing the implementation and effectiveness of this monitoring procedure.
• Department Heads: Responsible for ensuring their teams adhere to the modern slavery, human rights, and ethical trading policies.
• Employees: Responsible for reporting any concerns related to modern slavery, human rights abuses, and unethical trading practices.

 Risk Assessment

Safetynet Solutions will:

• Conduct regular (at least annual) risk assessments to identify potential risks of modern slavery, human rights abuses, and unethical trading within our operations and supply chains.
• Evaluate suppliers based on their location, industry, and past performance to determine the level of risk.
• Document and review risk assessment findings annually.

Supplier Audits

• Perform audits of suppliers to ensure compliance with our modern slavery, human rights, and ethical trading policies.
• Use a combination of announced and unannounced audits to verify adherence to ethical standards.
• Review supplier documentation, including labour contracts, wage records, and working conditions.
• Engage third-party auditors if necessary to ensure impartiality.

Employee and Supplier Training

• Provide regular training sessions for employees and suppliers on identifying and reporting modern slavery, human rights abuses, and unethical trading practices.
• Ensure training materials are up-to-date and reflect current laws and best practices.
• Document attendance and completion of training sessions.

 Reporting Mechanism

• Maintain a confidential reporting mechanism for employees and stakeholders to report concerns related to modern slavery, human rights abuses, and unethical trading practices.
• Ensure reports can be made anonymously if desired.
• Promote the reporting mechanism through internal communications and training.

Investigation Process

• Upon receiving a report, the Compliance Officer will:
  • Acknowledge receipt of the report within 5 business days.
  • Conduct a preliminary assessment to determine the validity of the report.
  • Initiate a thorough investigation if the report is deemed credible.
  • Provide feedback to the reporter on the outcome of the investigation.

Corrective Actions

• Implement corrective actions if any violations are identified during audits or investigations.
• Work with suppliers to address and rectify issues promptly.
• Terminate contracts with suppliers who fail to comply with our modern slavery, human rights, and ethical trading standards.

Documentation and Reporting

• Maintain detailed records of risk assessments, audits, training sessions, and investigations.
• Prepare an annual report summarising compliance efforts and findings.
• Share the report with senior management and relevant stakeholders.

Continuous Improvement

• Regularly review and update this monitoring procedure to ensure its effectiveness.
• Stay informed about changes in laws and best practices related to modern slavery, human rights, and ethical trading.
• Seek feedback from employees and stakeholders to improve monitoring processes.

When Engaging Suppliers

• We deploy Clear Communication of Expectations: We share our Supplier Code of Conduct, which outlines a supplier's modern slavery, human rights, and ethical trading standards.
  We ensure suppliers understand and agree to comply with these standards.
• We work in Collaboration and we Support: We offer training sessions and resources to help suppliers implement best practices where their own are requiring improvement,
  
  
• We reserve the right to carry out regular Audits and Assessments: We would conduct regular audits and risk assessments of suppliers to verify compliance. Use both announced and unannounced audits. This would apply where there was any indication of doubt in their supply.
• We Open Channels for Feedback: We establish open channels for clients to provide feedback on our policies and procedures and employ the same approach to our suppliers.
• We foster a partnership approach rather than a transactional relationship. Engaging in joint initiatives with suppliers to promote ethical practices.
• Transparency and Accountability: We encourage suppliers to maintain transparency in their operations and supply chains.
  We would implement accountability measures for suppliers who fail to meet our standards.

Key indicators for human rights compliance help organizations measure and ensure adherence to human rights standards. Here are some important indicators:

[1] Human rights indicators | OHCHR

[2] HUMAN RIGHTS INDICATORS

[3] Human Rights Indicators for Business