Anti-Slavery and Human Trafficking Policy
Our team and contractors affiliated with us in any capacity are bound to the terms of the statements below. This includes directors, officers, agency workers, seconded workers, volunteers, interns, agents, suppliers, vendors, external consultants, third-party representatives and business partners.
We strictly prohibit the use of modern slavery and human trafficking in our operations and are committed to acting ethically and with integrity in all our business dealings and relationships. Implementing systems and controls is our responsibility, and we make sure modern slavery is not taking place anywhere within our organisation. In effect, we expect the same high standards from all of our contractors, suppliers and other business partners.
However, this policy does not form part of any employee’s contract of employment and GOOD ADVICE UK may amend it at any time.
Modern Slavery and Human Trafficking
Modern slavery encompasses slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking occurs when a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
Our commitment is to ensure transparency in our own organisation and our approach to tackling modern slavery. This is consistent with our disclosure obligations under the Modern Slavery Act 2015.
Therefore, we expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- We have a zero-tolerance approach to modern slavery in our organisation.
- Those working for us or on our behalf should prevent, detect if able, and report any occurrence with the potential to be deemed as modern slavery in any part of our organisation.
- In fact, employees should engage, facilitate and report any activity that might lead to, or suggest, a breach of this policy.
- We keep our contracting processes under review with a risk-based approach. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach we also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, setting out the minimum standards required to combat modern slavery and trafficking.
- As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of vendors for their compliance with our Code of Conduct.
- If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
Responsibility for Policy
The Director(s) have full responsibility for enforcing the policy with Management, and our managers have a day-to-day responsibility to ensure legal and ethical compliance. They collectively monitor its use and effectiveness, deal with any queries, and audit internal control systems and procedures to ensure they are effective in countering modern slavery.
Managers 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.
Compliance with this Policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your Manager or the Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our organisation at the earliest.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your Manager or the Director or you may report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitutes any of the various forms of modern slavery, you must raise it with your Manager or the Director.
We aim 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 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 organisation.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager or the Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure.
Communication and Awareness of this Policy
Training on this policy and information regarding the risk our organisation faces against modern slavery will be provided as necessary.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We as a company may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
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GOOD ADVICE UK is registered in England and Wales as a Limited Company By Shares. Our Companies House Registration Number is: 06962398. We are regulated by the Office of the Immigration Services Commissioner (OISC).
GOOD ADVICE UK is also authorised by the Information Commissioner Office in the UK and is a member of major legal organisations operating in the legal and immigration sectors including JCWI and ILPA.