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BADGEMASTER LTD
ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY
Policy statement
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers.
In accordance with the UK Modern Slavery Act (2015) Badgemaster Ltd supports the objectives of the Act to eliminate slavery, servitude, forced or compulsory labour and human trafficking. We do not tolerate exploitation and we are committed to ensuring our practices and procedures and those of our suppliers are in line with this.
Badgemaster is committed to acting ethically with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place within either its own business or in any of its supply chains,
The Company expects the same high standards from all of its suppliers, contractors and other business partners and it expects that its suppliers will in turn hold their own suppliers to the same standards.
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants, business partners and suppliers.
Responsibility for the policy
The board of directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.
The general manager has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
Compliance
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chain, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. All employees are required to read, sign and comply with the company policy on this important subject.
If employees believe or suspect a breach of or conflict with this policy has occurred or may occur, they must notify their line manager or report it in accordance with the Company’s whistleblowing policy. They are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If they are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, they must raise it with their line manager, general manager or a board director. They can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of the policy
Immediate remedial action must be taken by any third party supplier found to be in breach of this policy and/or are found to have been involved in modern slavery.
Where no remedial action is taken Badgemaster may terminate its commercial relationship with suppliers, contractors and other business partners with immediate effect.
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
Due Diligence
The core business of Badgemaster is the manufacture and distribution of personalised name badges from its’ location in Nottinghamshire UK. In excess of 100 people are employed at the Badgemaster site dedicated to the design, sale, manufacture and distribution of these products in the UK. Approx. 85% of all products sold are produced in the UK by Badgemaster’s own employees with 15% of products (components and finished products) sourced from third party manufacturing partners.
Whilst under the terms of the Modern Slavery Act 2015 Badgemaster is under no obligation to visit any of its third party suppliers (UK or overseas) to ensure compliance with our policy of zero tolerance towards modern slavery Badgemaster will endeavour to the best of its ability will conduct due diligence to ensure compliance and will encourage its suppliers (UK and overseas) to conform to the standards expected. This will be achieved through a process of communication with all suppliers comprising of the distribution of this policy, letters of intent, questionnaires, requesting and acquiring copies of relevant certificates and other processes of due diligence. Where appropriate and cost effective, third party supplier visits will be conducted and assessments undertaken specifically reviewing the following areas.
(a) Policies that concern business relationships i.e. supplier code of conduct
(b) Recruitment policy
(c) Procurement policy
(d) Whistle-blowing procedures
(e) Migrant labour policies
(f) Child labour policy
(g) Child protection policy
(h) Gender policy
(i) Supplier code of conduct
(j) Employee code of conduct
(k) Policies concerning remedy and compensation for labour rights abuses
(l) Policies relating to staff training and increasing awareness of modern slavery
(m) Details of any mechanism by which standards or policies are enforced
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 have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour.
Badgemaster accepts that it has a responsibility through its due diligence processes 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 being adhered to, including freedom of movement and communications.
Ian P Bradbeer
Managing Director
August 2018
Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations operating in the UK with an annual turnover in excess of £36m to produce a ‘slavery and human trafficking statement for each financial year of the organisation’. Badgemaster Ltd has sales <£36m per annum so is not under any legal obligation to provide this.