First Adopted 13th September 2016
As a recruitment business, Penta Consulting maintains relationships with many different organisations in its supply chain, as well as employing directly a large number of workers.
The aim of the Company is to identify our responsibility by alerting staff to the risks, however small they are, in our business and in the wider supply chain. In the light of the general law on employment and human rights, and particularly, the Modern Slavery Act 2015, Penta has reviewed the existing compliance and risk management processes to determine which current measures exist, and what is required to prevent any slavery and human trafficking taking place in any part of our business and the chain we supply to.
Penta as a Company ensures that every employee is expected and encouraged to report any concerns to management and act upon it.
- PURPOSE OF THE POLICY
Under the Modern Slavery Act 2015 (“the Act”), modern slavery is a criminal offence. It can occur in various forms, including servitude, forced or compulsory labour and human trafficking, which would cause the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This Policy has been created with the aim to prevent any opportunities for the modern slavery to occur within Penta’s business and its supply chain. Penta Consulting is committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery does not take place in our business or businesses that Penta Consulting is involved with.
- PREVENTION OF MODERN SLAVERY
Penta is committed to ensuring that its business is carried out with transparency and that our approach to deal with modern slavery is spread across to our Contractors, Subcontractors and Clients, and remains in line with the obligations under the Modern Slavery Act 2015. Our processes are drafted in a specific way that helps to enforce specific prohibitions against the use of forced, compulsory or trafficked labour. All of our Contractors, Subcontractors and Clients are expected to act with the same approach.
Our Employees are required to understand modern slavery procedures to help prevention of it and to help conduct the business in a manner that any occurrence of modern slavery is avoided. Penta should also ensure that adherence to this policy forms part of the employment obligations under their contract of employment.
As part of our obligations under the Act we implemented the following measures:
- Conducting audits and risk assessments to determine which parts of the business require extra efforts and focus.
- Engaging with our clients, suppliers and contractors to instigate a better understanding of modern slavery and human trafficking and to ensure that modern slavery does not occur in their businesses.
- If appropriate, introducing screening programmes and self-reporting of our suppliers.
- Ensuring that modern slavery policy provisions remain as part of the clients’, suppliers’ and contractors’ contractual relationship with the right to audit their activities.
- RESPONSIBILTY OF THE POLICY
The responsibility for the prevention of modern slavery and human trafficking shall rest within the Company’s leadership. The Board of Directors of the Company shall ensure its implementation and compliance with the Company’s legal and ethical obligations.
Additionally, team leaders at all levels are responsible to ensure that those reporting to them understand and comply with the policy and that regular training is provided on modern slavery issues.
Any team member should approach either their senior team leader or an Executive Director or Human Resource Manager. In serious matters, the Managing Director should be approached.
Any person wishing to raise a concern with regard to breach of the Act should be entitled to do so in strictest confidence.
- SAFEGUARDING AND POLICY AWARNESS
All employees are encouraged to encourage openness and support with regards to genuine concerns. Penta shall ensure that no one suffers any detriment as a result of reporting any suspicion of modern slavery. All concerns will be taken seriously and communicated anonymously.
Penta believes in zero-tolerance approach to modern slavery and shall communicate the same to all its clients, suppliers, business partners and contractors.
- POLICY REVIEW
This Policy shall be initially adopted on the 13th September 2016 and shall be reviewed by the Company’s Board of Directors on a regular basis, (at least annually) and may be amended from time to time.
This Policy shall be published no later than the publication of the 2016 financial results.
This Policy has been accepted by the Board: