1. Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Cenergist has a zero-tolerance approach to modern slavery within its business and supply chains.
This policy applies to all persons:
- working for the Cenergist, or on our behalf, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, external consultants, and our contractors, external consultants, agencies, third-party representatives, and business partners (“Suppliers”).
- This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Cenergist is committed to:
- acting ethically and with integrity in all our business dealings and relationships;
- implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains; and
- ensuring there is transparency in our approach to tackling modern slavery in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all our Suppliers. As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our Suppliers will hold their own suppliers to the same high standards.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
2. Responsibility for the Policy
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. CGSTPOL049 Anti-Slavery Policy v1.0 Page 2 of 3
The Business Services Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
3. Identifying Modern Slavery
Modern slavery may be found in:
- our business, for example our cleaning and catering workforce;
- our supply chains;
- outsourced activities, particularly to jurisdictions that may not have adequate modern slavery safeguards.
There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:
- The person is not in possession of their own passport, identification or travel documents.
- The person is acting as though they are being instructed or coached by someone else.
- The person allows others to speak for them when spoken to directly.
- The person is dropped off and collected from work.
- The person is withdrawn or appears frightened.
- The person does not seem to be able to contact friends or family freely.
- The person has limited social interaction or contact with people outside of their immediate environment.
The above list is not exhaustive. A person may display several the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.
4. Reporting Modern Slavery
If you are unsure about whether the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your Cenergist line manager, or if you’re a supplier with your Cenergist contact. If you think that someone is in immediate danger, dial 999.
5. Communication and Awareness of this Policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. CGSTPOL049 Anti-Slavery Policy v1.0 Page 3 of 3
6. Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
7. Monitoring Our Procedures
We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make. This policy was approved by Mitesh Dhanak, Managing Director of Cenergist on 3rd September 2019.