Modern Slavery Policy
Modern Slavery and Human Trafficking Statement
Ventro Ltd are committed to ensuring that its staff are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and or similar human rights abuses.
We are also committed to ensuring our approach to tackling modern slavery in our own business and throughout our supply chains is consistent with our disclosure obligations under the Modern Slavery Act 2015. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain.
This statement sets out Ventro’s actions to understand all potential modern slavery risks related to the business along with the steps that Ventro Ltd has taken, and is continuing to take, to ensure steps are maintained to prevent both slavery and human trafficking within our business and supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Ventro has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Ventro is one of the leading specialists for Passive Fire Protection in the UK, specialising in the auditing, maintenance and installation of all passive fire safety systems and equipment including fire compartmentation, fire doors, fire stopping and fire dampers.
Working closely with housing associations, local authorities, universities and hotels, Ventro is raising awareness and helping the responsible persons in these organisations to comply.
Ventro is aware of our responsibilities towards employees and customers and expects all suppliers to the company to adhere to the same ethical principles. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.
Currently all suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with Ventro’s anti-slavery policy.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly-employed staff to safeguard against human trafficking or individuals being forced to work against their will
- Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities
- Safeguarding policies. We adhere to the principles inherent within both our safeguarding children and adults policies. These provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals
- Standards of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act
Our approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
- Ensuring our terms and conditions contain a clause on human rights issues and gives Ventro the right to terminate a contract for failure to comply with labour laws
- Using the standard Supplier Selection Questionnaire (SQ) that has been introduced (which includes a section on Modern Day Slavery)
Company staff must contact and work with the Procurement department when looking to work with new suppliers so appropriate checks can be undertaken.
We are zero-tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers to follow suit.
Our Processes for Managing Risk
In order to assess the risk of modern slavery, we use the following processes:
- Identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chains
- Review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks
- Protect whistle blowers
After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business our Modern Slavery Policy is included in our Employee Handbook.
Advice and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding children and adults training programmes, our safeguarding policies and procedures, and our safeguarding leads. It is also discussed at our compulsory staff induction training.
We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.
Our Key Performance Indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Ventro’s slavery and human trafficking statement for the financial year ending 31 March 2019. It has been approved by the Board of Directors, who will review and update it annually.