Anti-Slavery and Human Trafficking Policy
In meeting with our obligations under the Modern Slavery Act 2015, the company offers the following statement as our contribution in the prevention of modern slavery.
Modern slavery can take various forms, such as, servitude, forced or compulsory labour and human trafficking. Paradigm Shift Consulting has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chains, consistent with our obligations under the Modern Slavery Act 2015.
We also expect the same high standards from all our suppliers, contractors, and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse, and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery, or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Paradigm Shift Consulting accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
This policy applies to all individuals working for Paradigm Shift Consulting or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants, and business partners.
Responsibility for the policy
The directors have overall responsibility for ensuring that this policy complies with the Paradigm Shift Consulting’s legal and ethical obligations.
Dave Rushton (Director) has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery within our own business or supply chains.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
Compliance
The prevention, detection, and reporting of modern slavery in any part of Paradigm Shift Consulting’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for us or under the control of Paradigm Shift Consulting. You are required to avoid any activity that might lead to a breach of this policy. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with our Whistleblowing Policy.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of Paradigm Shift Consulting’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
Paradigm Shift Consulting aims to 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 or victimisation because of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and other business partners when entering into new or renewed contracts with them.
Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. Paradigm Shift Consulting may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.