Human Trafficking Policy

Human Trafficking & Slavery Statement

DEFINITIONS

Coppermill Ltd considers that modern slavery encompasses:

Human trafficking;

• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

 

COMMITMENT

Coppermill Ltd acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. Coppermill Ltd understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.

Coppermill Ltd has a zero tolerance policy towards modern slavery. It 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 Coppermill Ltd in pursuance of the services it provides is carried out wholly in Kingdom.

No labour provided to Coppermill Ltd in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Coppermill Ltd strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and exceeds those minimums in relation to its employees.

Coppermill Ltd offers employment contracts on a guaranteed hours basis only; no offers of employment are made on a zero hours basis.

Part-time and fixed-term employees within Coppermill Ltd are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, Coppermill Ltd is able to rely on objectively justifiable grounds.

Coppermill Ltd conducts staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and Coppermill Ltd company as appropriate.

 

 

 

POTENTIAL EXPOSURE

Coppermill Ltd considers its exposure to modern slavery to be extremely limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

In the operation of its business, Coppermill Ltd’s main supply chains are those related to the provision of services. Coppermill Ltd considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains.

 

STEP

Coppermill Ltd carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains.

Coppermill Ltd has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.

In accordance with section 54(4) of the Modern Slavery Act 2015, Coppermill Ltd has contacted (or attempted to contact) all first tier suppliers to set out our zero tolerance stance on modern slavery and to ensure that slavery and/or human trafficking is not taking place.

Coppermill Ltd has taken action to monitor reports of modern slavery and will cross reference such reports with our first tier supply chain. Coppermill Ltd will seek to discontinue business with any first tier supplier found by the enforcement authorities to be involved in modern slavery.

Coppermill Ltd encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

 

TRAINING

Upon commencement of employment, all employees undergo a structured induction process. All employees are made aware of Coppermill Ltd policies relating to standards of behaviour that it requires from them.

Coppermill Ltd also provides training on awareness of modern slavery to those within Coppermill Ltd who have been identified as having responsibilities in this regard, namely those involved in finance and procurement.

 

ASSESSMENT OF EFFECTIVENESS IN COMBATTING MODERN SLAVERY

To ensure effectiveness in combatting modern slavery, Coppermill Ltd maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in

 

its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.

Following a review undertaken Coppermill Ltd confirms its supplier list is up to date for the current financial year. There have been no reports that any of Coppermill Ltd’s suppliers have been involved in activities covered by the Modern Slavery Act.

 

POLICIES

Coppermill Ltd also has a Corporate Social Responsibility Policy which further defines its stance on modern slavery. In addition, a Whistleblowing policy is in place which encourages the reporting of any wrongdoing which is in the public interest.

 

GROUP DATA PROTECTION & COMPLIANCE OFFICER

Coppermill Ltd has a Data Protection & Compliance Officer,  to whom all concerns regarding modern slavery should be addressed. Coppermill Ltd Data Protection & Compliance Officer undertakes an annual review of Coppermill Ltd’s obligations towards eradicating modern slavery within its organisation and supply chains.

 

REVIEW

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to all companies within and associated to Coppermill Ltd. It is reviewed for each financial year.