ANTI-MODERN-DAY SLAVERY POLICY
What Is Slavery?
The Modern Slavery Act (MSA) 2015 covers four activities:
- Slavery – Exercising powers of ownership over a
- Servitude – The obligation to provide services is imposed by the use of
- Forced or compulsory labour – Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
- Human trafficking – Arranging or facilitating the travel of another person with a view to their
This policy covers all four activities.
How is it relevant to us?
Modern slavery is a complex and multi-faceted crime and tackling it requires many organisations and individuals to play a part. At first glance, individuals may think this subject is irrelevant to us, but it’s not.
At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.
The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
With this in mind, we need to pay particularly close attention to our supply chain, especially those areas which have historically proven to be at risk of the activities in:
- Outsourced activities such as cleaning, waste management,
- Short term hire of low skilled labour – sourcing of raw materials from certain locations in the
Quora Group’s Directors and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
Everyone must observe this Policy and be aware that ‘turning a blind eye’ is unacceptable and simply not an option.
Quora Group will:
- Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and
- Be clear about our recruitment and selection
- Examine our supply chains and be clear with key suppliers our expectations regarding the
- Lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for
- Seek to raise awareness so that our colleagues know what we are doing to promote their
- Make a clear statement that we take our responsibilities to our employees and our clients
- Listen and be approachable to colleagues.
- Respond appropriately if they are told something that might indicate a colleague is in an exploitative
- Remain alert to indicators of slavery.
- Raise the awareness and ensure all employees are provided with a copy of this policy and be aware of their responsibilities.
- Use their experience and professional judgement to gauge situations as colleagues we all have responsibilities under this
Whatever your role or level of seniority, you must:
- Keep your eyes and ears open – if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting
- Follow our reporting procedure below (Appendix 1) if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
- Tell us if you think there is more, we can do to prevent people from being
The principal areas of risk we face, related to slavery and human trafficking, include:
- Certain areas of the supply chain may be identified as being at a higher risk – these may be identified in our due diligence reviews see Supply Chains
- Recruitment either through agencies or direct we manage these risk areas through our procedures set out in this policy.
We make a clear statement that we take our responsibilities to our employees, people working within our supply chain and our clients seriously, and this is updated once a year.
We tell the companies we do business with, that we are not prepared to accept any form of exploitation. From the date of this policy, all relevant supplier contracts will contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.
We apply reasonable due diligence to risk assessing our supply chain and use the following mechanisms to do this:
- Supplier mapping initially performed on spend level and then industry sector to identify key
- Risk Assessment of spend areas in relation to the supply chain and their propensity of historically proven
- Training and knowledge sharing for key
- Ensuring all suppliers deemed “at risk” are fully supportive to the aims of this policy, (including asking for copies of their Anti Modern Slavery Statement and Policies).
- Harmonising those processes which are already mutually inclusive of the aims of this policy into the due diligence.
- If any issues are identified then this is escalated to the senior stakeholders in the business, with all methods of remediation to be available (up to and including exiting the relationship with the supplier).
Recruitment Using Agencies.
- Quora Group follows firm policy and only uses agreed specified reputable recruitment
- We expect all recruitment agencies with whom we engage to fully comply with the Modern Anti-Slavery Act 2015 and any subsequent legislation:
- Are free from ethical
- Are transparent, accountable, and auditable.
- If the Company has reason to believe that any recruitment agency has failed to meet these standards, the Directors should be informed and any contracts with them would be
- We keep agents on the list under regular reviews.
- We ensure staff have a written contract of
- We ensure staff are legally able to work in the
- We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to. If, through our recruitment process, we suspect someone is being exploited, the Directors will be informed, and the Directors will follow our reporting
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
However, the following key signs could indicate that someone may be a slavery or trafficking victim:
- The person is not in possession of their own passport, identification, or travel
- The person is acting as though they are being instructed or coached by someone
- They allow others to speak for them when spoken to directly.
- They are dropped off and collected from
- The person is withdrawn, or they appear frightened.
- The person does not seem to be able to contact friends or family freely.
- The person has limited social interaction or contact with people outside their immediate
This list is not exhaustive. Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it to the Directors who will follow our reporting procedures.
- Talking to someone about your concerns may stop someone else from being exploited or
- If you think that someone is in immediate danger, dial 999.
- Otherwise, you should discuss your concerns with the Directors who will decide a course of action which may include contacting the Police or the Gangmasters Licensing Association (GLA).
- Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the Directors before taking any further action.
We ensure that all employees are made aware of this policy, and their obligation to comply with this policy.
Monitoring Our Procedures
We will review our Anti-Modern-Day Slavery Policy every two years or if the need arises. We will provide information and/or training on any changes we make.
- Employees need to report their concerns to the Directors as soon as
- The Directors will determine their course of action depending on circumstances reported to them g., reporting to a supplier or the appropriate authorities.