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Modern Slavery & Human Trafficking Policy Statement for the financial year 2019-2020

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets
out the steps that Silwood Facilities Limited (‘SFL’) has taken and is continuing to
take to ensure that modern slavery or human trafficking is not taking place within our
business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour
including child labour. We have a zero-tolerance approach to modern slavery and
we are committed to acting ethically and with integrity in all our business dealings
and relationships and to implementing and enforcing effective systems and controls
to ensure modern slavery is not taking place anywhere in our own business or in any
of our supply chains.

It is the policy of SFL to:
ensure a high level of understanding of the risks of modern slavery and human
trafficking in our supply chains and our business by providing training to relevant staff; pay all staff at least the minimum wage rate applicable; comply with all legislation, importantly the Immigration Act 2015; strive to build long standing relationships with our suppliers & sub-contractors;
ensure that all employees are made aware of their individual obligations in respect of modern slavery & human trafficking; encourage the reporting of concerns and the protection of whistle blowers, by way of our Whistleblowing Procedure; ensure that all staff, including temporary workers, have a written contract of employment; we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will ensure all staff know their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to;
use indicative pricing statistics to assess fees from agencies offering or charging suspiciously low rates; and ensure compliance of this policy through management meetings, site visits, internal & external audits.

Our Suppliers:
SFL remains committed to maintaining and improving systems and processes to prevent human rights violations related to our own operations & that of our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners and expect them to have suitable anti-slavery and human trafficking policies & processes. SFL vets its external contractors to ensure they have the requisite accreditation and are appropriately qualified for the roles they are asked to undertake. These services are UK based and we therefore consider them as lower risk. Given what SFL understands to be a low risk profile of anyone supplying us with services being involved in slavery and/or human trafficking, we believe our current procedures and ability to rely on regulatory oversight in relation to professional services are sufficient.

As part of our contract with suppliers, we require that they confirm to us that: They have taken steps to eradicate modern slavery within their business; They hold their own suppliers to account over modern slavery; and They pay their employees at least the national minimum wage / national living wage as currently legislated. We may terminate a contract with a supplier at any time should any instances of modern slavery or human trafficking come to light.


Approval for this statement:
This statement was approved by the Board of Directors on 5th September 2019

Mark Lee

Read our singed policy here:

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