Modern Slavery & Human Trafficking Policy

This policy statement ensures that Milestone Industrial Flooring Ltd complies with section 54 of the Modern Slavery Act 2015, and sets out the responsibilities for Milestone Industrial Flooring Ltd our employees, suppliers, Labour Only Sub Contractors and Sub contractors.

Milestone Industrial Flooring Ltd is committed to ensuring that all of its business operations are free from involvement with slavery or human trafficking.

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, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and, we are 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 own business or in any of our supply chains

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners.

As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy:

  • Applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, Labour Only Sub Contractors, Sub contractors, external consultants, third-party representatives and business partners
  • Does not form part of any employee’s contract of employment and we may amend it at any time.

 

Responsibility for the Policy

The Managing Director, supported by the Milestone Industrial Flooring Senior Management team, has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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.

The Health & Safety Manager 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.

All staff and employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Health & Safety Manager.

 

Compliance with the Policy

This policy document will be made available to all employees who must ensure that it is read, understood and complied with at all times.

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.

All employees, suppliers, Labour Only Subcontractors and Subcontractors:

  • Are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  • To notify their Line Manager or a member of the senior management team as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
  • 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.

If it is believed or suspected that a breach of this policy has occurred, or that it may occur, all employees, suppliers, Labour Only Subcontractors and Subcontractors must notify their Line Manager, or a Senior member of the Milestone Industrial Flooring Management Team.

Please note that, where appropriate, and with welfare and safety for all as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.

If any individual is unsure about whether a particular act, 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, they should raise it with their Line Manager, or a Senior member of the Milestone Industrial Flooring Management Team.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If any individual believes that they have suffered any such treatment, they should inform their Line Manager, or a Senior member of the Milestone Industrial Flooring Management Team.

If the matter is not remedied, and the individual is an employee, they should raise it formally using our existing Grievance Procedure.

 

Communication and awareness of this Policy

Awareness 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.
  • Will, in addition to guidance notes issued to Senior Managers, be provided as required.
  • Will be provided for specific projects / locations if identified as High Risk during the pre-construction / construction risk assessment process.

Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

We will ensure that all commercial agreements include an obligation on our suppliers to operate in accordance with the Modern Slavery Act 2015, and to ensure that any of their suppliers and sub-contractors also operate in accordance with the Act.

 

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

In support of our zero-tolerance approach we will, if as a result of investigation, if it is deemed appropriate, terminate our relationship with any individuals and organisations working on our behalf if they breach this policy.

 

Monitoring, Auditing and Review

This policy will be reviewed annually and at other intervals that may be required following:

  • Further changes in the published, or similar aligned, legislation.
  • As a result of issues raised by regular audits.
  • Following any investigation into issues or concerns raised by our staff, employees, subcontractors, suppliers plus other interested third parties.
  • The results of monitoring, audit and review of our existing aligned policies and procedures for example, Industrial Audits, Salary/Wage Surveys and Right to Work Checks.

 

Peter Harrison

Managing Director

Milestone Industrial Flooring Ltd                                       Reviewed: July 2019