Modern Slavery Statement
Introduction
Ebbsfleet Development Corporation, in line with UK government policy, is committed to eradicating modern slavery from the domestic and global economy.
We recognise that Modern Slavery is a crime and a violation of fundamental human rights. We are aware that Modern Slavery takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Modern Slavery is the term used within the UK and is defined within the Modern Slavery Act 2015.
The Act categorises offences of Slavery, Servitude and Forced or Compulsory Labour and Human Trafficking (the latter of which comes from the Palermo Protocol).
The Corporation continues to adopt a zero tolerance to modern slavery, human trafficking, all forms of servitude and forced and compulsory labour.
We fully support the government’s objectives to eradicate all forms of modern slavery and human trafficking.
We continue to set high standards of impartiality, integrity, transparency, and objectivity. We will ensure that our activities and those of our contractors operate to the highest level of ethical standards operating under sound governance arrangements.
The Corporation is also committed to the effective management and application of public funds in accordance with Managing Public Money carried out in the spirit of, as well as to the letter of, the law:
- in the public interest
- to high ethical standards
- achieving value for money
EDC’s responsible employment practices
As a responsible employer the EDC takes the following steps:
Child labour shall not be used: we do not employ anyone under the age of 16, although occasional placements for school pupils may also be accepted.
Living wages are paid: our lowest paid salary range is above the living wage.
Regular employment is provided: all our employment contracts have an adequate notice period.
Whistleblowing: The Corporation has a whistleblowing policy and a Whistleblowing Board Champion.
Procurement, Contracts and Supply Chains
Modern slavery risks are much higher in some activities than others, and therefore the Corporation has adopted a risk-based approach to our procurement activities and our supply chain. We expect all suppliers as part of our procurement processes, to consider:
- the known risks within each sector/industry
- work force information
- supplier base location
The Corporation contracts are let to address specific needs. This commonly involves specialist skills. These tend to involve UK based people and organisations.
The Corporation contracts are let to address specific organisational needs. This commonly involves specialist skills. These tend to involve UK based people and organisations. The Corporation contract includes Terms and Conditions which enable us to address risks of modern slavery.
The Corporation contract includes terms and conditions which enables us to address risks of modern slavery. Our supply chain is comprised of external suppliers that provide the products and services that the Corporation purchases, including, but not limited to, providers of:
- Cleaning services
- Merchandise and marketing materials
- IT outsourcing
- Photography
- Food and beverages
- Maintenance services
- Specialist consultancy services
- Recruitment
- Office supplies
Policies in relation to slavery and human trafficking
We expect all of our Delivery Partners and companies we engage with to ensure their goods, materials, and labour-related supply chains are:
- fully comply with the Modern Slavery Act 2015; and are
- transparent, accountable, and auditable; and are
- free from ethical ambiguities
And that they provide modern slavery training both internally to staff and externally to their contractors and sub-contractors.
We call upon all organisations we engage with to influence their global supply chains by improving transparency, accountability, and training so that together we can help the government eradicate the injustice and brutality of modern slavery and human trafficking.
The Corporation has internal policies in place and ensures that such policies are reviewed on a regular basis, including an Equality & Diversity Policy and Recruitment & Selection Policy which reflects its commitment to acting ethically and with integrity in all of its business relationships and in implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place within the Corporation or its supply chains.
The Corporation’s Director of Corporate Services will lead actions if there are any allegations of modern slavery within EDC’s supply chains.
Ebbsfleet Development Corporation will continue to review and improve the processes and systems to tackle modern slavery in our supply chains and ensure our procurement policies comply with PPN 06/20.
Due Diligence Processes
As part of the Corporation’s due diligence processes into modern slavery and human trafficking, the supplier approval process is key to ensure that slavery is not present within the Corporation or its supply chain. Specifically:
- We endeavour to establish and build transparent relationships with our suppliers and are clear on our expectations of business behaviour
- We adopt a zero-tolerance approach to slavery and human trafficking; we expect all suppliers to comply with our values to demonstrate this commitment
- We expect all suppliers to comply with all relevant anti-slavery and human trafficking legislation
Risk & Mitigation
During our business activities, the potential risk of modern slavery arises from the following key scenarios:
- The risk that we procure goods or services for our own consumption where there is an unethical supply chain
- The risk that we partner alongside organisations with an unethical supply chain, or we engage, invest, lend or sell to organisations with an unethical supply chain
These risks are mitigated by:
- Using thorough procurement processes in which suppliers demonstrate compliance with the requirements of the Modern Slavery Act
- Reputational risk is mitigated by an upfront compliance requirement in our tender and procurement documentation, enforced at delivery by contractual conditions and agreements and including appropriate termination clauses
Public reporting of non-compliance
Individuals who have reasonable suspicion or evidence of non-compliance with the Modern Slavery Act in connection with any EDC supply chain or third-party contractor we engage with are encouraged to report their concerns to the following email address; contactus@ebbsfleetdc.org.uk.
Alternatively, if you hold information that could lead to the identification, discovery and recovery of victims of modern slavery or human trafficking in the UK, you can contact the Modern Slavery Helpline or report it online.
Modern Slavery Helpline: 08000 121700
Victim Support
If you think you are a victim of modern slavery or human trafficking, use the victim support link to contact the Modern Slavery Helpline. Trained operators will help you to understand what is available including information, advice, and ways to access government-funded support.
The Modern Slavery Helpline is confidential, but, if you don’t want to give your name, that is fine.
Support telephone line: 08081689111
The Gang Masters and Labour Abuse Authority (GLAA)
The Gang Masters and Labour Abuse Authority (GLAA) is a Non-Departmental Public Body (NDPB) governed by an independent board, working in partnership to protect vulnerable and exploited workers.
The role of the GLAA is to protect vulnerable and exploited workers. Through the intelligence they receive from inspections, the public, industry and other government departments, they investigate reports of worker exploitation and illegal activity such as human trafficking, forced labour and illegal labour provision, as well as offences under the National Minimum Wage and Employment Agencies Acts.
The GLAA will investigate all aspects of labour exploitation in England and Wales but will also work with partner organisations such as the police, the National Crime Agency and other government law enforcement agencies to target, dismantle and disrupt serious and organised crime across the UK.
Reporting abusive practice can be undertaken by visiting the GLAA website.