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The Growth Company Modern Slavery Procedure for Suppliers   

November 2017, V.1

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, 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. 

The Modern Slavery Act 2015 places legal obligations on all large companies who do business in the UK to publish a “slavery and human trafficking statement” to disclose what steps the company has taken, if any, to ensure that slavery and human trafficking is not taking place in its own operations or its supply chain. 

Our Commitment at GC 

The Growth Company (GC) and its subsidiaries commit to uphold the highest standards of ethical conduct and integrity in the way we conduct our business. We strive to ensure that slavery and human trafficking is not taking place in our supply chain or in any of our business activities and take a zero tolerance approach to modern slavery in all its forms. We look to our partners, customers, suppliers, associates and contractors to adopt and commit to these same principles. GC publishes its modern slavery statement on the GC website annually. 

This procedure is in support of our zero tolerance stance on the exploitation of labour and our commitment to ensure that our procurement is undertaken in an ethical and responsible manner.   

The Growth Company Modern Slavery Procedure for Suppliers

Large Suppliers 

1. Any business with a global turnover of £36m which carries out business in any part of the UK is required by law to publish annually a Slavery and Human Trafficking Statement. It is incumbent on GC to require any such business or organisation with which we are engaging with, as defined above, to first provide a copy of its statement which we should retain on file. Where the contractual relationship with the supplier extends beyond one year, GC reserves the right to request updated copies of the supplier statement in each subsequent contract year. 

2. GC will not enter into any business relationship with any large business which is unable to provide such a statement, however, we may enter into discussions with the business and outline an acceptable timescale to allow the business to remedy their position and produce a Statement. Where (in GC’s sole discretion) the supplier fails to meet our requirements in this important area, GC will cease trading with the supplier.  

3. It is not GC’s responsibility to assess the quality or veracity of that statement but if the statement discloses that the business has taken no steps to ensure that slavery and human trafficking is not taking place within its operations (which is permissible under the law), the supplier statement will be referred to the relevant Managing Director at GC, who may define the corrective actions we require to continue to engage with the supplier. Where (in GC’s sole discretion) the supplier fails to meet our requirements in this important area, GC will cease trading with the supplier.    

Micro, Small and Medium Sized Business Suppliers 

4. Businesses with a turnover below £36m are not covered by the Modern Slavery Act.  However, in line with our commitment in this area, GC and its subsidiaries require that our suppliers confirm that they abide by the labour principles set out above.

5. This commitment is secured through the tendering or contracting process, where we ask suppliers to commit to GC labour principles (See Annex 1 below).    

6. Where the supplier is unwilling to commit to these principles, the instance will be referred to the relevant Managing Director, who may define the corrective actions required to continue to engage with the supplier. Where (in GC’s sole discretion) the supplier fails to meet our requirements in this important area, GC will cease trading with the supplier.  

Governance 

Where a supplier has been found in breach of this procedure by the relevant Managing Director, the instance will be referred to the Internal Audit Team, who will keep a record of any breaches and actions. The Internal Audit Team will notify the Board of breaches through the Audit Committee.  

Suspected Instances of Modern Slavery 

Where GC has identified or suspect a specific case of modern slavery, which is an illegal workforce practice, relevant Managing Director or their appointee, will report the case to the police. 

Further Information Available to Businesses

Modern Slavery Act 2015 http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted

Support for Businesses 

For businesses based in Greater Manchester, The Business Growth Hub (one of the GC’s companies) provides fully funded support services to enable businesses to grow and develop.  https://www.businessgrowthhub.com/

Government Guidelines and Resources  https://www.gov.uk/government/collections/modern-slavery

▪ The UK Government provides a 24-hour modern slavery helpline that victims, employers and members of the public who may encounter modern slavery can call for expert support and advice. 0800 0121 700

Stronger Together was launched in October 2013 as a business led multi-stakeholder collaborative initiative to equip UK employers and recruiters with the practical knowledge and resources to tackle modern slavery in their business and supply chains by providing free good practice guidance and tools through www.stronger2gether.org

▪ One of GC’s companies (Centre for Assessment) provide a commercial, one day service to help businesses understand the requirements of the Modern Slavery Act, evaluate activity already underway to mitigate modern slavery risks and advise on any improvements needed. Details of this service can be found at the following web-site link: http://www.centreforassessment.co.uk/about-us/our-services/modern-slavery-assessment/. There are other suppliers who provide similar services and suppliers are under no obligation to engage with CFA for this service. 

Annex 1 

Growth Company Responsible Procurement Principles V.1

GC is committed to upholding the highest ethical conduct in its activities. We seek to work with businesses and organisations who respect the following values and principles in their business; 

Labour Principles 

▪ Employment is freely chosen. GC has a zero-tolerance approach to the exploitation of workers

▪ There is no exploitation of children

▪ Living wages are paid as defined by all minimum national legal requirements

▪ Working conditions are safe and hygienic

▪ Working hours are not excessive and comply with all relevant national legislation

▪ No discrimination is practised

▪ Regular employment is provided 

▪ The rights of staff to freedom of association and collective bargaining are respected

▪ No harsh or inhumane treatment of staff is allowed

Environmental Sustainability  

GC is committed to principles of sustainability and seeks to minimise the impact of our activities on the environment; we look to our partners, suppliers and associates to work with us to achieve these aims and promote environmental sustainability in our business. 

The following principles should be considered in the products and services used and supplied to GC;

▪ Goods and services should be produced and provided in ways which minimise their embodied energy and the energy they consume over their lifetime

▪ Durable product that can be reused, refilled or recharged to extend its life

▪ Made of recycled materials, maximising post-consumer content

▪ Recyclable after the intended use and diverted from Landfill

▪ Non-toxic or minimally toxic, preferable biodegradable 

▪ Sustainable Sources – recognised certification only 

Packaging, Transport and Waste

▪ Packaging is minimised 

▪ Packaging used contains high recycled content and is recyclable

▪ Schemes for end-of-life equipment and packaging recycling

▪ Consideration of transport distances and methods through the supply chain, from source, production through to final delivery point.

Bribery, Corruption and Conflicts 

The Growth Company recognises that bribery is contrary to fundamental values of integrity, transparency and accountability and undermines organisational effectiveness.  GC staff may not accept gratuity, advantage or personal favour from suppliers or other business partner organisations. 

We require our suppliers (including their sub-contractors) and other business partner organisations to show commitment to the prevention, deterrence and detection of bribery and implement effective anti-bribery measures in their business and supply chain.   

Furthermore, in principle no company or supplier may attempt to obtain a contract, if there is any direct link, whether through family or interests, with a member of GC staff unless this is properly declared at all stages of the process and that it can be clearly proven that at no point during the procurement process has there been any unfair advantage gained.