Anti Slavery & Human Trafficking
Policy

SAFEGUARDING AGAINST MODERN SLAVERY

at Halstock

At Halstock, we are committed to upholding human rights and maintaining the highest ethical standards in everything we do. This page outlines our policy on modern slavery and human trafficking, and the steps we take to safeguard against it within our business and supply chain.

INTRODUCTION FROM THE COMPANY DIRECTORS

Slavery and human trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Halstock Cabinet Makers Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Halstock Cabinet Makers Ltd has a zero-tolerance approach to any form of modern slavery.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

OUR BUSINESS

Halstock Cabinet Makers Ltd is a privately-owned business based near Yeovil, Somerset and operating throughout the U.K (United Kingdom) (United Kingdom), but primarily in London and the Home Counties. We design, manufacture, and install bespoke furniture, joinery, and interiors in the high-end residential sector.

OUR SUPPLY CHAINS

Our supply chain includes the sourcing of raw materials for use in our own workshops, sub-contract labour for additional manufacturing work for our projects and for site installation, and the sourcing of specialist-fabricated materials.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Halstock Cabinet Makers Ltd are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, to ensure slavery and human trafficking is not taking place anywhere in our supply chains

DUE DILIGENCE FOR PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk, we operate several internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:

SLAVERY POLICY AND HUMAN TRAFFICKING POLICY

Recruitment Policy: – We operate a robust recruitment policy, including conducting eligibility to work in the UK (United Kingdom) checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. All personnel are paid at least the minimum wage in line with current government legislation.

Verification of Labour on Site: – Our Supervisors undertake individual personnel checks prior to commencement of work to ensure labour reporting directly to site have the correct paperwork and CSCS card scheme requirements, including photographic identification.

External Audit: – The company is audited externally by the CITB Levy Board of its payroll and labour force.

Subcontractors: – Approved subcontractor lists are used where internal verification processes are undertaken in accordance with our Health & Safety policies and procedures and ensuring personnel are registered within the construction industry scheme.

Suppliers of materials: – The company uses reputable suppliers for the provision of materials.

Monitoring: – Monitoring is undertaken regularly by Senior Management of our policies, procedures, and processes throughout the company.

Whistle blowing and reporting: – We operate a whistle blowing procedure so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals. The company’s policy on whistle blowing encourages all its workers, customers, and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

SUPPLIER ADHERANCE TO OUR VALUES

We have a zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

This policy on modern slavery will be communicated to all suppliers, contractors, and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.

Halstock Cabinet Makers Ltd will conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that organisation has never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions.

Our anti-slavery policy forms part of our contract with all suppliers and they will be required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we will require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business

2. They hold their own suppliers to account over modern slavery

3. They pay their employees at least the national minimum wage in line with current legislation (UK based suppliers)

4. We may terminate the contract at any time should any instances of modern slavery become known.

TRAINING

Halstock Cabinet Makers Ltd has provided training to employees by briefing them on the company slavery and human trafficking policy and raising the awareness. We expect employees to refer to this policy and understand what is required of them in relation to modern slavery so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

OUR PERFORMANCE INDICATORS AND REVIEW

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Board of Directors on a regular basis (at least annually) and may be amended from time to time.

APPROVAL FOR THIS STATEMENT

This statement was approved by the Board of Directors of Halstock Cabinet Makers Ltd.