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Modern Slavery Policy


1. What is Modern Slavery?

Modern slavery is a broad term used to encompass slavery, servitude, forced or compulsory labour and human trafficking. It includes both adults and children being forced to work against their free will and, in essence, involves one person depriving another person of their freedom. It is a crime and a gross violation of human rights that affects people almost everywhere, including in the UK. A person is considered to be in modern slavery if they are:

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness seep into instances of human trafficking, slavery or forced labour in a work environment.

Businesses have a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are adhered to, including freedom of movement and communications.

2. What is the Scope of Modern Slavery?

The International Labour Organisation estimates that there are 21 million people in forced labour across the world; other estimates go as high as 46 million people. The UN holds slavery to be the second largest criminal industry in the world. Whilst slavery has been illegal in the UK since 1833, bonded and forced labour, trafficking and exploitation persist. It is estimated that there are 13,000 people in slavery in the UK. High risk areas are prostitution, domestic servitude, the construction industry and agriculture.

3. Impact of the Modern Slavery Act

In the first year of the Act, 3,266 potential victims were identified in the UK and referred for support, a 40% increase on the previous year, and 289 offences were prosecuted.

4. Key Provisions of the Modern Slavery Act

The Act applies to organisations with a global turnover of over £36m which carry on all or part of their business in the UK. It places an obligation on these organisations to take steps to ensure that slavery and human trafficking are not taking place both within their own operations and within their supply chains; transparency within supply chains is an important provision within the Act.

All obligated organisations must publish a ‘slavery and human trafficking statement’ for each financial year, this statement disclosing the steps the organisation has taken to ensure that slavery and human trafficking is not taking place in its own operations and in its supply chains. This applies to all financial years ending on or after 31 March 2016.

5. Company Statement

Adams Morey Ltd is committed to ensuring that no modern day slavery takes place within the company’s operations and, as far as practicably possible, that no such slavery exists within the company’s supply chains.

6. Application of Policy

This policy applies to all persons working for or on behalf of the company in any capacity, including employees, directors, agency workers, temporary workers, volunteers, contactors and external consultants.

7. Compliance Officer

The company will appoint a designated individual to act as Compliance Officer who will be responsible for ensuring the implementation of this policy and for acting as a focal point for receiving and dealing with any evidence of modern slavery arising within the company or its supply chains. The individual will liaise with the board of directors to ensure appropriate systems and procedures for monitoring for evidence of modern slavery are in place.

The board of directors has overall responsibility for ensuring this policy complies with the company’s obligations under the Modern Slavery Act and that all those under its control comply with it.

8. Compliance

All employees of Adams Morey Ltd and those working for the company in whatever guise must ensure they understand and comply with this policy.

The company is committed to preventing slavery in its business and its supply chains and it is the responsibility of all those who are involved in the business to avoid any activity that might lead to a breach of this policy.

It is also incumbent on all those involved in the business to be aware of any breach of this policy or of any signs of modern slavery, both within the business and within its supply chains, and to report any such incidence to their manager or to the Compliance Officer with immediate effect. If there is any uncertainty or ambiguity about the incident, then it should still be discussed with a manager or the Compliance Officer.

The company operates a Whistle-blowers’ Policy whereby it both encourages the reporting of such incidents and protects those working for it from any detrimental treatment as a result of this reporting.

9. Due Diligence

The company will, through its policies and procedures and its method of operating, ensure it minimises the possibility of modern slavery occurring within the company and its associated supply chains.

To ensure this we operate the following:

The company also operates a preferred supplier list and undertakes due diligence before including a supplier on this list. This due diligence includes an online search to ensure the organisation in question has never been convicted of offences relating to modern slavery. The majority of our supplies (over 65%) are from our franchisors, DAF and Fiat, and, of the remainder, a significant proportion is from local suppliers with whom we have personal contact and knowledge of their operations.

We will seek to ensure that all new suppliers comply with the Modern Slavery Act and will also carry out a review of our existing suppliers to ensure they comply.

Within the company itself we will undertake training of key personnel, particularly managers and those involved in procurement, to ensure they are fully aware of the requirements of this policy and the need to ensure compliance within the company and its supply chains.

10. Risk Assessment

The company, under the leadership of the Compliance Officer, will undertake a risk assessment of both the company and its supply chains to identify the key areas of risk for modern slavery. This risk assessment will be repeated annually, more frequently if it is felt necessary.

Any risk areas identified will be investigated and monitored to ensure compliance with this policy with remedial action being taken as appropriate.

11. Training

Training will be given to managers and those involved in procurement to ensure they are fully aware of the requirements of this policy. Other employees will be trained as appropriate.

12. Key Performance Indicators

We have agreed on two key performance indicators:

 13. Annual Statement

The company will produce an annual statement as noted in 4 above.

14. Review

This policy will be reviewed by the board of directors on an annual basis and updated as necessary.



Approved by board of directors: Mike Fennell - Managing Director


Date: 2nd January 2019



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