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Modern Slavery Act 2015

The Modern Slavery Act 2015 came into effect on 29th October 2015. The Act seeks to address the role of businesses in preventing modern slavery from occurring in organisations and their supply chain. It requires businesses in any sector which meet defined criteria to produce a slavery and human trafficking statement each financial year. For further information on the act please click here.

 

What we have done

OL & Edward which operates across UK and our supplier countries, is committed to eradicating modern slavery and human trafficking. Our efforts include the following: 

 

OL & Edward Limited has the following policies:

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

 

These include the following: 

  • Recruitment and selection policy - Our hiring procedure is in place to guarantee that we choose people who share our values, have high ethical standards, are the best fit for the job, and, most importantly, meet the requirements for working in the United Kingdom.

  • Supplier code of conduct - Suppliers of services and goods from the UK and beyond are part of OL & Edward supplier network. Each of our supplier network organisations is responsible for adhering to all applicable rules and regulations. OL & Edward, on the other hand, has communicated with all of its present UK supplier network organisations to underline the Act's criteria and to emphasise that we will only engage with organisations that meet those requirements and share our commitment to preventing modern slavery.

  • Whistleblowing policy - Our Whistleblowing Policy is designed to ensure that our staff can raise their concerns about wrongdoing or malpractice within OL & Edward’s organisation and supply chains without fear of victimisation, subsequent discrimination, disadvantage or dismissal.

  • Staff code of conduct - Our Code of Conduct is ingrained in our culture, and it serves to ensure that all workers are aware of their responsibilities and commitment to working ethically, as well as to guide them in making the best decisions possible. It contains information about our company principles, human rights, and safeguarding, all of which are closely aligned with modern slavery criteria.

  • Procurement policy - We conduct due diligence on organisations before dealing with them, which includes a review of critical policies. We've also sent out mandatory evaluation questionnaires to help us understand their present controls and processes in the fight against modern slavery and human trafficking.

  • Safeguarding policy - Our Safeguarding policy outlines the legal requirements for providing a duty of care, promoting positive wellbeing, and establishing a clear mechanism for raising concerns in order to protect people's welfare. This includes worries about modern slavery. Throughout our UK operations, we have a Modern Slavery Prevention and Reporting procedure. The Safeguarding Policy and its representative are known to all coworkers.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures: 

  • Internal supplier audits.

  • External supplier audits.

  • Checking certain suppliers with external third parties for any slavery or human trafficking risks.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains.

  • Monitor potential risks in our business and supply chains

  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

  • Provide protection for whistleblowers.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

  • Evaluating the slavery and human trafficking risks of each new supplier.

  • Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We consider that we operate in a high-risk environment because construction is one of the most vulnerable industries to modern-day slavery. One cause is the high demand for low-skilled, low-wage manual labour, which has been highlighted as a source of forced labour. It's also typical to work for a temporary staffing agency. Workers who fill such positions are frequently uneducated and unemployed. Finally, the construction business is characterised by long and complicated supply chains that span multiple countries and involve numerous stakeholders.


We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

  • We will contact suppliers to enquire about their modern slavery practices every 12 months.

  • We will train our staff about modern slavery issues and increase awareness within the Company.

Training our staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers:

  • How to identify the signs of slavery and human trafficking.

  • What initial steps should be taken if slavery or human trafficking is suspected.

  • How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.

  • What external help is available.

  • What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.

 

The statement was approved by the board of directors.

Olga Muksinova & Livia Kudina
OL & Edward Limited

Date 25/02/21