modern Slavery Act
Statement
OUR POLICIES AND CONTROLS
The prevention, detection and reporting of Modern Slavery in any part of Clementine Services’ business or supply chains is the responsibility of all those working for Clementine or under Clementine’s control.
Our Clementine Services Anti-Slavery Policy can be found on all internal directories.
DUE DILIGENCE PROCESSES
Clementine Services have a number of policies and procedures in place, including:
- Equal opportunities to prohibit discrimination
- Anti-harassment & bullying
- Grievance, fraud & risk and anti-bribery to enable the workforce to raise concerns should they arise.
APPROACH
Clementine has a zero tolerance approach to any form of modern slavery and trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings and we expect our supply chain, contractors, employees and all other business partners to commit to the same, including implementing and enforcing effective systems and controls to prevent and deter modern slavery.
We have a number of related policies and strategies which will support us in ensuring compliance with the Modern Slavery Act, these include:
- Safeguarding Adults and Children policies
- Procurement strategy
- Whistle-blowing policy
- Recruitment policies
We are therefore well placed to make a positive contribution to preventing opportunities for modern slavery to occur within our business and our supply chain.
PROCUREMENT & SUPPLY CHAIN
We are committed to ensuring that there is transparency in our business and our approach to tackling modern slavery is consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and we are evolving and updating our procurement and contracting processes to include specific prohibitions against the use of forced, compulsory and trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
Clementine procures a wide range of goods and services via a diverse and varied supply chain, including:
- Property related services (construction and maintenance)
- Facilities management services (field service)
- Communications and IT equipment services
- Various professional services
- Office equipment and supplies
- Utilities
The biggest risk to our organisation of falling foul of the Modern Slavery Act is through our procurement of goods and services. Whilst we cannot 100% guarantee supplier adherence with the requirements of the Modern Slavery Act we will endeavour to eliminate the risks as much as possible.
We will do this by:
Ensuring that our procurement processes, supplier code of conduct and contractual terms include specific provision relating to the Modern Slavery Act and by exercising our right to audit their activities to check compliance.
TRAINING
To increase awareness and ensure a high level of understanding of the risks of Modern Slavery and Human Trafficking, Clementine Services include our Modern Slavery Policy in our employee handbook which all new staff receive, and existing staff have access to at all times.
COMMUNICATION OF THIS POLICY
Our zero-tolerance to modern slavery will be communicated:
- To all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
- To employees via the staff intranet and completion of training incorporating modern slavery and human trafficking.
We will communicate this policy regularly.
RISK MANAGEMENT AND ASSESSMENT OF EFFECTIVENESS
As a business we are committed to working with only reputable contractors and suppliers and continually evaluate our supply chains. Risk assessments are regularly carried out and included in new supplier correspondence. We promote policies such as the Clementine Services Whistle Blowing Policy which encourages anyone to report any suspicion of malpractice or illegal acts.
FURTHER INFORMATION AND ADVICE
Modern Slavery helpline – 0800 0121 700
APPROVAL
This updated modern slavery and human trafficking statement was approved by the Board of Directors of Clementine Services Limited on
Date: 1st February, 2024
Mark Black LLB, MBA
CEO
On behalf of The Board of Directors