Modern slavery policy and statement

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Introduction

Whilst Tended (“the Company”) has an annual turnover less than the required threshold of £36m per annum, we take seriously our obligations to prevent Modern Slavery and Human Trafficking in all our business operations, including those of our extended supply-chains, and choose to publish the Modern Slavery policy, and annual statement for FY25.

We all have a duty to be alert to risks, however small.  Employees and contractors are expected to report their concerns and management to act upon them.

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1. Policy

Tended (“the Company”) adopts a zero-tolerance approach to, and is fully committed to preventing, modern slavery in its operations and in its supply-chain.

We pay particular attention to:

• Our supply chain
• Any outsourced activities, particularly in jurisdictions that may not have adequate safeguards
• Cleaning and catering suppliers that we use

Supporting policies and procedures include business ethics, grievance, whistleblowing, recruitment (conducting appropriate checks on all employees, contractors and suppliers to ensure we know who is working for us).

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Managers will:

• Listen and be approachable to colleagues
• Respond appropriately if they are told something that might indicate that a colleague is in an exploitative situation
• Remain alert to indicators of slavery and use their experience and professional judgement to gauge situations

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Employees will:

• Remain alert to indicators of slavery
• Follow our reporting procedures if they become aware of indicators that a colleague or other party is being exploited or ill-treated
• Tell their manager if they think the Company can do more to prevent exploitation

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The Company:

• Checks supply chains where appropriate to ensure the potential for slavery and human trafficking is reduced
• Expects our suppliers to check their supply chains to ensure the potential for slavery and human trafficking is reduced
• Only uses specified, reputable recruitment agencies on a vetted and regularly reviewed preferred supplier list
• Ensures all employees have a written contract of employment, and all contractors have a consultancy agreement
• Always ensures staff are legally entitled to work in the UK, for UK-based roles
• Provides information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits to which they may be entitled
• Provides training to those employees who are involved in managing recruitment and managing suppliers, and provides general awareness through this Policy
• Will monitor our procedures

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2. Organisational structure and supply chains

2.1 The Company currently operates in the UK, though has some clients overseas

2.2 The Company will assess whether particular activities or countries are high risk concerning modern slavery or human trafficking

2.3 We assess all suppliers for compliance with our Modern Slavery policy, including that they have their own Modern Slavery policy and are diligent within their own supply chains

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3. Responsibility for initiatives

3.1 Policies: The COO is responsible for creating and reviewing this policy. This Policy and Statement is reviewed and updated at least annually.

3.2 Risk assessments: The COO and Compliance Manager are responsible for risk assessments in respect of modern slavery by a process of assessing;

3.2.1 Internal recruitment and employment processes;

3.2.2 Use of subcontractors; and

3.2.3 Third parties on whom we rely 

3.3 Due diligence: All employees are responsible for due diligence about known or suspected instances of modern slavery and human trafficking.

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4. Training

4.1 To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company uses resources such as from the Gangmasters and Labour Abuse Authority (GLAA) and the Global Slavery Index to educate themselves on how to spot modern slavery.

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5.Supplier due diligence

5.1 The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers 

5.2 The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier

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This policy has been approved and authorised by:

Signed by: Benjamin Turner, COO

Date: 8th September 2024

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