ProGARM Limited – Modern Slavery and Human Rights Policy (2021 Edition)
ProGARM is committed to driving out acts of modern-day slavery and human trafficking within its business and from within its supply chains, including subcontractors, and partners.
The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within ProGARM.
The Company considers that modern slavery encompasses:
• Human trafficking.
• Forced work, through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse.
• Being dehumanised, treated as a commodity, or being bought or sold as property.
• Being physically constrained or to have restriction placed on freedom of movement.
As part of the companies’ due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.
The company will not support or deal with any business knowingly involved in slavery or human trafficking.
In general, the Company considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Any supplier deemed high risk will be required to adhere to your modern slavery policies as a contract condition and be required to trained on modern day slavery policies.
The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers, before, during and at the end of the contract.
The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has taken the following steps to ensure that modern slavery is not taking place:
• Reviewed and updated our supply chain onboarding procedure.
• Reviewed and mitigated risk.
• Developed a code of Ethical Code and Employment Standards Policy alongside this policy and communicated to all employees and suppliers.
A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.
This policy statement will be reviewed annually and published.