UTCompliance, in association with Unique Tenders Limited
1. Introduction
UTCompliance and Unique Tenders Limited recognise that modern slavery represents one of the most pressing human rights challenges of our time. UTCompliance stands firmly against all forms of modern slavery, human trafficking, and exploitation. This commitment goes beyond mere legal compliance—it reflects our core values and belief in the fundamental dignity and rights of all human beings.
Modern slavery manifests in various forms, including forced labour, debt bondage, human trafficking, and exploitative practices that strip individuals of their freedom and basic human rights. As a responsible business entity, we acknowledge our role in combating these practices through rigorous policies, thorough due diligence, and active engagement with our stakeholders.
This policy document serves as a cornerstone of our ethical framework, demonstrating our unwavering commitment to operating with integrity and ensuring that our business practices positively impact the communities we serve. We recognise that addressing modern slavery requires continuous vigilance, adaptation, and improvement of our practices.
2. Purpose and Objectives
This policy establishes a comprehensive framework for preventing, identifying, and addressing modern slavery risks within our operations and supply chains. Our objectives extend beyond basic compliance with the Modern Slavery Act 2015, aiming to set industry-leading standards for ethical business conduct.
We seek to create lasting change through several key objectives:
First, we aim to establish robust systems for identifying and addressing modern slavery risks before they materialise. This involves comprehensive risk assessment protocols, due diligence procedures, and regular monitoring of our operations and supply chains.
Second, we work to foster a culture of awareness and responsibility among our employees, suppliers, and partners. Through education, training, and clear communication of expectations, we ensure that all stakeholders understand their role in preventing modern slavery.
Third, we strive to create positive change within our industry by demonstrating that ethical business practices and commercial success are not mutually exclusive. We believe that by setting high standards and sharing best practices, we can contribute to the broader fight against modern slavery.
3. Scope and Application
The reach of this policy extends across UTCompliance’s ecosystem. It applies to all employees, regardless of their role or employment status, from senior executives to temporary staff. This universal application ensures consistency in our approach to preventing modern slavery.
Beyond our immediate workforce, the policy encompasses all business relationships, including:
Our direct suppliers and their extended supply chains, recognising that modern slavery risks often lie hidden in complex supply networks. We expect our suppliers to cascade our standards throughout their own supply chains, creating a multiplier effect in promoting ethical practices.
Contractors and service providers who work with or on behalf of UTCompliance, ensuring that all services provided to us are delivered in accordance with our ethical standards.
Business partners and joint venture participants, as we believe in extending our influence to promote ethical practices beyond our direct control.
4. Risk Assessment and Due Diligence Framework
Our approach to risk assessment and due diligence operates on multiple levels to ensure comprehensive coverage of potential modern slavery risks. We conduct detailed initial assessments of all new business relationships, followed by regular reviews and ongoing monitoring.
The assessment process begins with a thorough mapping of our supply chains, identifying areas where modern slavery risks are most likely to occur. This includes consideration of geographical factors, industry-specific risks, and the nature of labour practices in different sectors.
Our due diligence procedures involve in-depth evaluation of potential partners’ policies, practices, and commitment to preventing modern slavery. We examine their track record, verify their compliance with relevant legislation, and assess their ability to meet our ethical standards.
Regular audits and assessments help maintain high standards throughout our business relationships. These may be announced or unannounced, and include site visits, document reviews, and worker interviews where appropriate.
5. Implementation and Monitoring
The effective implementation of this policy relies on clear allocation of responsibilities and robust monitoring systems. Senior management takes direct responsibility for policy implementation, demonstrating our top-down commitment to preventing modern slavery.
We maintain detailed records of all due diligence activities, risk assessments, and actions taken to address identified concerns. This documentation supports our compliance efforts and helps us track progress over time.
Regular reviews of our anti-slavery measures ensure their continued effectiveness. We analyse key performance indicators, including the number of risk assessments conducted, training completion rates, and the resolution of reported concerns.
6. Training and Capacity Building
Our training program goes beyond basic awareness to develop deep understanding of modern slavery issues among our stakeholders. Initial training for all employees covers the fundamentals of modern slavery, including how to identify potential signs and the proper channels for reporting concerns.
Advanced training is provided to staff in high-risk areas or those with specific responsibilities related to supply chain management and procurement. This includes detailed guidance on conducting risk assessments, implementing due diligence procedures, and managing relationships with suppliers.
We regularly update our training materials to reflect new developments, emerging risks, and lessons learned from our experience. This ensures our approach remains current and effective in addressing evolving challenges.
7. Reporting and Remediation
We maintain multiple channels for reporting concerns about potential modern slavery issues, ensuring that all stakeholders have access to confidential reporting mechanisms. These include:
A dedicated ethical concerns hotline that operates 24/7 and accepts anonymous reports.
An online reporting platform that allows detailed documentation of concerns while maintaining reporter confidentiality.
Direct access to designated ethics officers who can provide guidance and support.
When concerns are raised, we follow a structured investigation process that ensures thorough examination while protecting those involved. Our remediation procedures focus on addressing immediate concerns while also implementing preventive measures to avoid similar issues in the future.
8. Review and Continuous Improvement
This policy undergoes annual review to ensure it remains effective and relevant. The review process considers:
Changes in legislation and regulatory requirements Emerging best practices in modern slavery prevention Feedback from stakeholders Lessons learned from our experience implementing the policy Results of our monitoring and assessment activities
We actively seek input from employees, suppliers, and other stakeholders during the review process, ensuring our policy continues to meet the needs of all affected parties while maintaining its effectiveness in preventing modern slavery.
9. Governance and Accountability
The Board of Directors maintains ultimate responsibility for this policy and UTCompliance’s anti-slavery efforts. A dedicated Ethics Committee oversees policy implementation and reports directly to the Board on modern slavery prevention activities.
Clear lines of accountability extend throughout UTCompliance, with specific responsibilities assigned at each level. Regular reporting ensures visibility of our anti-slavery efforts and enables prompt action when needed.
We maintain transparent communication about our anti-slavery efforts, publishing annual statements that detail our activities and progress in this area. This transparency helps hold us accountable to our commitments and demonstrates our ongoing dedication to eliminating modern slavery from our operations and supply chains.
10. Supply Chain Management and Partner Engagement
Our commitment to preventing modern slavery extends throughout our supply chain through comprehensive engagement with suppliers and business partners. We recognise that successful prevention requires active participation and commitment from all parties involved in our business operations.
Supply chain transparency forms the foundation of our approach. We maintain detailed records of our direct suppliers and work continuously to improve visibility into sub-suppliers and extended supply chain networks. This transparency enables us to better understand and address risks at all levels of our supply chain.
When engaging with new suppliers, we conduct thorough pre-qualification assessments that evaluate their commitment to preventing modern slavery. This process includes detailed questionnaires, document reviews, and where appropriate, site visits. We pay particular attention to suppliers operating in high-risk industries or geographical areas, implementing additional oversight measures as needed.
Existing suppliers undergo regular performance reviews that include evaluation of their anti-slavery measures. These reviews consider not only their direct operations but also their management of their own supply chains. We work collaboratively with suppliers to address any identified gaps or concerns, providing guidance and support for improvement where needed.
11. Worker Protection and Support
Protection of workers’ rights stands at the heart of our anti-slavery efforts. We implement comprehensive measures to ensure all workers, whether directly employed or working within our supply chain, are treated with dignity and respect.
Our worker protection framework begins with clear employment standards that prohibit any form of forced labour, human trafficking, or exploitation. We ensure all workers receive formal employment contracts in languages they understand, detailing their rights, responsibilities, and terms of employment.
We maintain strict controls over recruitment practices, prohibiting the charging of recruitment fees to workers and ensuring all recruitment activities are conducted ethically and transparently. Special attention is paid to the use of labour agencies or third-party recruiters, with additional oversight measures implemented to prevent exploitation.
Support services are available to all workers, including access to confidential counselling, legal advice, and assistance in reporting concerns. We recognise that vulnerable workers may face additional challenges and provide targeted support to address their specific needs.
12. Compliance Monitoring and Enforcement
Our compliance monitoring system operates continuously to ensure adherence to this policy across all areas of our operations. This system combines regular scheduled assessments with random spot checks to maintain comprehensive oversight of our anti-slavery measures.
Internal audits occur at planned intervals, examining documentation, processes, and practices to verify compliance with policy requirements. These audits extend beyond paper reviews to include workplace observations and confidential worker interviews, providing deeper insight into actual working conditions and practices.
External assessments by independent third parties complement our internal monitoring efforts. These assessments provide objective evaluation of our anti-slavery measures and help identify areas for improvement. We carefully select assessment partners based on their expertise and credibility in modern slavery prevention.
When non-compliance is identified, we implement a structured enforcement process that balances the need for immediate action with opportunities for improvement. Minor infractions trigger corrective action plans with clear timelines for implementation. Serious violations may result in immediate termination of business relationships, particularly when there is evidence of deliberate exploitation.
13. Stakeholder Communication and Transparency
We maintain open and transparent communication about our anti-slavery efforts with all stakeholders. This commitment to transparency helps build trust, demonstrates accountability, and encourages others to strengthen their own anti-slavery measures.
Our annual modern slavery statement provides detailed information about our prevention activities, including specific actions taken, challenges encountered, and progress made. This statement goes beyond minimum legal requirements to provide meaningful insight into our anti-slavery work.
Regular updates to employees keep them informed about our anti-slavery initiatives and reinforce their role in prevention efforts. These updates include specific examples of good practice, lessons learned from incidents or near-misses, and recognition of exemplary efforts in preventing modern slavery.
We engage actively with industry peers, civil society UTCompliance’s, and government agencies to share experiences and best practices in modern slavery prevention. This collaborative approach helps strengthen collective efforts to combat modern slavery across our industry.
14. Crisis Response and Remediation
Despite strong preventive measures, we maintain comprehensive procedures for responding to potential modern slavery incidents. Our crisis response framework ensures swift, appropriate action when concerns are identified.
The initial response focuses on ensuring the immediate safety and well-being of potential victims. We work with appropriate authorities and support organisations to provide necessary assistance, including safe accommodation, medical care, and legal support where required.
Investigation procedures follow established protocols that protect victim privacy while gathering necessary information. These investigations seek to understand root causes and identify systemic issues that may require broader attention.
Remediation efforts address both immediate incidents and underlying factors that may have contributed to the situation. This includes reviewing and strengthening preventive measures, updating policies and procedures, and implementing additional safeguards as needed.
15. Documentation and Record Keeping
Maintaining comprehensive records of our anti-slavery efforts supports compliance, enables effective monitoring, and demonstrates due diligence. Our documentation system captures all relevant activities, decisions, and outcomes related to modern slavery prevention.
We maintain detailed records of:
- Risk assessments and due diligence activities
- Training programs and participant completion
- Supplier evaluations and monitoring results
- Incident investigations and remediation efforts
- Policy reviews and updates
These records are maintained securely while ensuring appropriate accessibility for authorised personnel. Regular reviews of documentation help identify trends, patterns, and areas requiring additional attention.
16. Innovation and Continuous Development
We recognise that effectively combating modern slavery requires ongoing innovation and adaptation to emerging challenges. Our approach emphasises continuous development of new tools, techniques, and processes to strengthen our prevention efforts.
We actively explore new technologies that can enhance our ability to identify and address modern slavery risks. This includes digital monitoring tools, data analytics capabilities, and improved tracking systems for supply chain transparency.
Research partnerships with academic institutions and specialised organisations help us stay current with emerging trends and best practices in modern slavery prevention. These partnerships also contribute to broader understanding of effective prevention strategies.
We regularly evaluate new approaches to worker engagement, supplier monitoring, and risk assessment, implementing those that show promise for strengthening our anti-slavery measures.
17. Policy Integration
This modern slavery policy operates as part of our broader ethical business framework, integrating with other key policies and procedures to ensure comprehensive coverage of human rights and labour standards.
Integration with procurement policies ensures anti-slavery considerations are embedded in purchasing decisions and supplier selection processes. Human resources policies incorporate specific provisions related to ethical recruitment and employment practices.
Regular review of policy integration ensures consistency across our governance framework and identifies any gaps requiring attention. This integrated approach strengthens overall effectiveness of our anti-slavery measures while promoting efficiency in implementation.
