Document Modern Slavery Policy 
Date of original document  September 2023
Original document author  Morgan Jones
Latest document revisions  
Revised by  
Approved by  Hazel Israel
Next review date  November 2024

Introduction 

This Policy sets out the steps Bantani Cymru will take to comply with the Modern Slavery Act 2015 and our commitment to acting ethically and with integrity in our organisation’s relationships. 

This document sets out the policy of Bantani Cymru with the aim of the prevention of opportunities for modern slavery to occur within the organisation. This policy’s use of the term “modern slavery” has the meaning given in the Act, as outlined below. 

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). The Act is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery. Modern slavery can occur in various forms (see below for details), 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 operate a number of policies which reflect our commitment to acting properly in all of our organisational relationships and to implementing and enforcing effective systems and controls. Our policies which contribute to minimising the risk of modern slavery and human trafficking in our organisation include our: 

–    Recruitment Policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employed staff 

–    Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities 

–    Safeguarding Policy. We adhere to the principles within both our safeguarding children and vulnerable adults policies. These also provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business 

–    Whistleblowing Policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, without fear of reprisals 

We will continue to review our policies to ensure that they are effective and appropriate. Subject to changes in legislation, this Policy will be reviewed and updated accordingly (at least annually). 

Slavery can take many forms. These include: 

–    Child trafficking 

–    Forced labour 

–    Forced marriage 

–    Sexual exploitation 

–    Criminal exploitation 

–    Domestic servitude 

–    Labour exploitation 

–    Organ harvesting 

Bantani Cymru will not tolerate slavery in any aspect of our organisation. We hold ourselves accountable and we will ensure compliance with the provisions of the Modern Slavery Act 2015 in relevant aspects of our work. 

Policy outline 

This Policy document provides an overview of our zero-tolerance approach to modern slavery. We have determined that there are areas of risk related to the activities that we carry out, so we provide guidance to colleagues on modern slavery by: 

–    Providing training 

–    Raising awareness at Anti-Slavery Day 

–    Directing colleagues to relevant websites and help/reporting lines (see below) 

Risk management 

We have identified that we do have a potential exposure to risk related to modern slavery. However, our Modern Slavery Policy and policies around recruitment, safeguarding, etc ensure that we have effective controls in place. Staff are encouraged to ‘speak up’ through our whistleblowing policy. 

To manage this risk, we will work with suppliers and contractors to acknowledge our commitment to combat slavery by inserting relevant clauses into our contracts and agreements. 

Training and awareness raising 

To ensure a high level of understanding of the risks of modern slavery, we annually review awareness and training and we will be carrying out an internal awareness campaign, with the aim being to help colleagues to better understand the risks and how we as an organisation are working to manage this and mitigate modern slavery. 

How to report modern slavery concerns 

Colleagues who suspect incidents or signs of modern slavery should: 

–    In the first instance, all modern slavery crimes should be reported to the local police by dialling 999 

–    If colleagues hold information that could lead to the identification, discovery and recovery of victims, they should contact the Modern Slavery Helpline on 0800 0121 700 

–    For more information, colleagues are advised to visit: www.unseenuk.org 

–    Alternatively, colleagues can make calls anonymously to Crimestoppers on 0800 555 111 

Monitoring, review and performance information 

The monitoring and effectiveness of this policy will be managed by the directors, which includes: 

–    Recording and monitoring any incidents or reports made to us which conflict with our values 

–    Treating all reports and incidents in line with our other policies 

–    Reviewing and strengthening our centralised processes and policies, taking into account a range of risks, including slavery and human trafficking.