Section 54 of The Modern Slavery Act 2015 places an obligation on UK businesses with a turnover greater than £36 million to produce a modern slavery statement. This statement therefore explains the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business.
Startin Group is an ethical employer and is committed to taking steps to abolish slavery and human trafficking wherever it may exist, and are committed to making continual progress in this regard.
The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.
We have a zero-tolerance policy towards modern slavery and will refrain from entering into business. And/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
The labour supplied to the Group in pursuance of the services it provides is carried out wholly in the United Kingdom.
No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under UK employment legislation and in many cases exceeds those minimums in relation to its employees.
Zero Hours, Part time and fixed-term employees within the group are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, the Group is able to rely on objectively justifiable grounds.
The group considers its exposure to modern slavery to be limited. In terms of our suppliers, which are diverse, we do what is realistically possible for a company of our size in our supplier sourcing and procurement process. We look to work with businesses that display a quality and ethical aspect to the goods and services they provide. Though we take this general view, it is ultimately our supplier’s duty to ensure compliance with legislation, human rights and ethical codes of conduct. In addition, we use our reasonable endeavours to conduct risk assessments of the third parties we work with and investigate, where feasible, the working conditions of their employees.
Upon commencement of employment, all employees undergo a structured induction process. All employees are made aware of the Group policies relating to standards of behaviour that it requires from them. In terms of MSA specifically, we are developing a process whereby our management teams are made aware of the topic of modern slavery, and channels through which concerns can be raised and subsequently addressed if deemed necessary by the Directors.
This statement is made in pursuance of section 54(1) of the modern Slavery Act 2015 and applies to all companies within the Startin Group. It is reviewed for each financial year.
This statement relates to the 2018 financial year which ended on the 31st December 2018 and is approved by:
The Directors of Startin Group.
Date of approval: January 2019