- About this Policy
We are committed to implementing and consistently applying practices across all areas of our organisation to contribute to combatting slavery and human trafficking and have a positive influence on people’s lives.
Violations of fundamental human rights are still happening every day. These incidents take place in various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which remove a person’s rights and liberties to exploit them for personal or commercial gain.
This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and outlines the procedures and practices the NFM makes to minimise the risk of Modern Slavery throughout the organisation.
Our aim is to ensure our practices are consistently evaluated and improved upon to make certain that the we act in an ethical manner and with integrity in our operation by implementing processes that ensure there is no modern slavery or human trafficking in our supply chains or in any part of our business.
- Operational steps
4.1 Employment of staff
Most of our people are directly employed; few services are outsourced or supplied through
agencies. We mitigate the risk of modern slavery occurring by ensuring that directly employed staff are recruited following robust recruitment and candidate selection policies which includes conducting eligibility to work in the UK checks. There is also a Whistleblowing Policy through which staff can raise concerns.
4.2 Supply Chain
Our suppliers fall into the following categories:
- Building / Facilities Management services
- Cleaning, Catering and Security services
- Exhibition Fabrication & Manufacturing
- Goods for resale in our shop
- HR, IT and finance services.
We expect all of our suppliers to meet the standards we wish to uphold, section 4.3 describes the actions we will take in order to complete our due diligence.
4.3 Procurement Procedures and development
Our existing procurement procedures are detailed within our financial policy, however these only detail financial systems. In order to comply with this policy, by January 2023, we will aim to have developed a set of broader procurement procedures.
These procedures will be used to encourage our suppliers to provide assurances that they have undertaken appropriate due diligence to ensure that there is no slavery or human trafficking within the supply chains that serve their contract. We also expect our suppliers and contractors to provide training to their staff. The areas of assurance expected are:
4.3.1 Policy – Supplier shall be able to supply a Modern Slavery policy or similar.
4.3.2 Regulatory compliance – Suppliers shall comply with all national and other applicable law and regulations.
4.3.3 Child labour – Supplier to confirm child labour is not used in any element of the supplier’s business and in areas where risk is higher, they participate in and contribute to policies and programmes to reduce this risk.
4.3.4 Right to a national minimum wage – Wages paid for a standard working week meet national legal standards.
4.3.5 Avoidance of excessive working hours – Standard working hours must comply with national laws and national benchmark industry standards; whichever affords greater protection to the employee.
4.3.6 Discrimination – A policy of equality for all shall be in place and there shall be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on legally defined protected characteristics.
4.3.7 No harsh or inhumane treatment – Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse of other forms of intimidation is prohibited.
4.3.8 Safe and Healthy Working Conditions – Providing a safe and healthy working environment bearing in mind international standards, the prevailing knowledge of the industry and of any specific hazards.
4.3.9 Environment – To comply with all environmental legislation, regulations and all local laws which relate to the organisation’s environmental aspects to facilitate the protection of the environment.
4.4 Staff Training & Development
Awareness and understanding of the risks of modern slavery and human trafficking in our operation will be raised through the provision of appropriate staff guidance and training. This includes reviewing and sourcing appropriate and effective training for colleagues as well as those involved in the procurement of goods, services and works, so all are equipped to identify and assess risks within our supply chains.
We will develop measures to assess how effective we have been in ensuring that slavery and human trafficking is not taking place in our operations and any part of our supply chains. Where appropriate we will update the procurement processes and contract documentation to ensure any new requirements or legislation are incorporated as appropriate.