Last updated 11-08-2020
Purpose of this Policy
This policy sets out ITI Operations Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. ITI Operations maintains relationships with many different organisations in its supply chain, as well as directly employing large numbers of people. In the light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, ITI Operations are absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chain is free from slavery and human trafficking.
We are committed to acting ethically and with integrity in all our business transactions and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our businesses and supply chain.
This policy sets out our approach on modern slavery and explains how Employees can identify instances of this and where they can go for help and guidance.
Following the adoption of this policy, this will be reviewed by the Company’s Senior Management Team as required and may be amended where necessary.
Organisational Structure and Supply Chains
This policy covers all the activities of ITI Operations throughout its UK locations. It governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.
We expect all who have, or seek to have, a business relationship with ITI Operations and/or any member of our company, to familiarise themselves with our policies and to act at all times in a way which is consistent with our Anti-Slavery Policy.
The HR Department will liaise with other relevant departments such as the Quality and the Legal team to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking is carried out as required.
HR will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this Policy.
Relevant Policies and Practices
ITI Operations Limited operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
ITI Operations Policy on whistleblowing encourages all its employees, customers and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can refer to the ITI Operations Whistleblowing Policy which is available on the Company intranet. The nature of the complaint will determine the next course of action.
We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. Personnel responsible for recruitment activities are advised to adhere to this policy by ensuring that strict verification of potential Employee’s right to work is carried out before any offer of employment is made.
ITI Operations Limited expects its supply chain to adhere to recruitment practices to ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy.
Awareness & Performance Indicators
As well as training employees, ITI Operations will raise awareness of modern slavery issues by emailing the Anti-Slavery and Human Trafficking Policy to all employees as well as it being made available on the intranet. Further to this, ITI Operations plan to continue to create awareness on modern slavery issues through training workshops and annual update communications. Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.
ITI Operations Limited understands modern slavery risk is not static, therefore, we will continue to mitigate this risk and review our key performance indicators to ensure effective systems and controls are in place to safeguard against any form of modern slavery taking place within our business or supply chain.
A current version of this document is available to all members of staff on the corporate intranet. It does not contain confidential information and can be released to relevant external parties.