MODERN SLAVERY AND HUMAN TRAFFICKING TRANSPARENCY STATEMENT
COMET BUSINESS GLOBAL SOLUTIONS LTD
STATEMENT: 2021 – 2022
Introduction
The Modern Slavery Act 2015 is a provision against crime and fundamental violations of human rights that can take place in numerous forms such as slavery, servitude, forced/compulsory labour, and human trafficking.
We are highly committed and in accordance with the Modern Slavery Act 2015; the purpose of this statement is to shed light on the relevant policies, procedures and practices that combat slavery and human trafficking within our organisation.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the United Kingdom and to safeguard employees from any abuse, coercion or exploitation.
Organisational Structure
Comet Business Global Solutions Ltd are a team of experienced Security, Privacy, Legal and Technology Specialists, offering affordable IT, Privacy, Security and Data Governance solutions for over 50 clients including Department of Health & Social Care, NHS Federation of Doctors, Primary care networks, GP practices, Youth Justice Board and many more.
Policy
Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place within our organisation.
Modern Slavery and Human Trafficking Standard
The Modern Slavery and Human Trafficking Standard sets out the minimum acceptable levels of behaviour required of all staff, as well as setting out the activities that will be undertaken to identify and address the risk of modern slavery within our organisation and supply chains.
Whistleblowing Policy
Whistleblowing Policy is communicated to employees during induction. The intention of the policy is to outline the process for employees to report instances of corruption, malpractice, criminal behaviour and failure to deliver proper standards of service, where confidentiality is required. This policy is integral in preventing occurrences of modern slavery and human trafficking by providing an avenue whereby any suspected instance can be reported without fear of repercussions.
The whistleblowing facility is always available to employees and any implications in terms of modern slavery can be brought to attention by any employee anytime.
We are a small organisation and do not have multiple chains of command.
Supply Chain Charter
Supply Chain Charter sets out expectations placed on the supply chain, including the prevention and elimination of modern slavery and human trafficking in their organisations and supply chains. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
Conditions of Employment Manual
The Conditions of Employment Manual establishes conditions, processes, protocols, rights and responsibilities governing the employment of all employees. This extends to equal opportunities, pay, working hours, training and development, conduct and discipline and employee relations. This forms part of the contract of employment between Comet Business Global Solutions and its employees. The establishment of regulated working practices alongside standards to be upheld ensures the just and fair treatment of all employees.
Colleagues Professionalism – Standards and Expectations
As consultants, we ensure that we meet the highest level of professionalism. standards which are applicable to the conduct and work of employees. This includes, but is not limited to, competence, reporting, personal responsibility, procedural use and adherence and equality, diversity and inclusion. Upholding these standards within the workplace is essential in ensuring the correct treatment of workers as well as the workers themselves maintaining the highest standards of conduct and ethical behaviour, whether operating at home, abroad or in managing the supply chain.
Equal Opportunities Policy
The Equal Opportunities policy documents our commitment to providing equal opportunity for employment, advancement and equitable treatment, whilst outlining the responsibilities of employees and their managers to avoid and report instances of harassment. Our commitment to overcoming any barriers to equal opportunity and complying with its obligations is emphasised and this helps to ensure the fair and equitable treatment of all employees by providing a consistent approach to developing the skills and attributes of all employees whilst valuing their respective abilities.
Dignity at Work Policy
The Dignity at Work Policy covers harassment of, and by, all workers engaged to work for our organisation: this includes employees, contractors, agency workers or anyone working in any other capacity on behalf of our organisation. This policy provides recourse to the disciplinary procedure where an instance of harassment or other occurrence of indecent treatment of an employee occurs. Moreover, the policy sets an expectation of the obligation on employees to intervene in instances of harassment, if they feel able to do so, or at the very least report it immediately to a manager.
The Dignity at Work Policy has the effect of reducing, or curtailing, any forms of inhuman or degrading treatment in the workplace, not only by those employed by us but also any person onsite and is therefore also compliant with Articles 3 and 4 of the European Convention on Human Rights.
Resource Management
The Resource Management Map provides an illustration of the route or process to be followed when assigning a surplus or shortfall in manning. This includes planning, assignment and review.
Supply chain
We have introduced a mandatory requirement for suppliers to declare their compliance with Section 54 of the Modern Slavery Act as part of the pre-qualification questionnaire within our procurement process. Any suppliers failing to meet this requirement are not permitted to continue in the procurement process. We are also planning to work with key suppliers to ensure they are real living wage employers.
Effective action taken to address modern slavery
We will undertake the following activities to address modern slavery risks:
- Development and roll out of ethics training to key staff in the organisation and in doing so drawing particular attention to the need to develop positive action in terms of a strong reporting culture and encouraging the use of the whistleblowing facility
- Address whether there are modern slavery risks during the contract strategy stage
- Continue to promote staff awareness of the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking, in line with the requirements of Procurement Policy Note 05/19 – Tackling Modern Slavery in Supply Chains
- Continue to engage with its supply chain to obtain evidence of the controls in place within their organisations to eradicate modern slavery and human trafficking, including looking at the lower tiers of their supply chains
- Continue with compliance checks as part of the new supplier registration process. This requires suppliers to provide evidence of compliance with relevant legislative, safety, health, environment and quality principles and procedures, where appropriate, before being eligible to provide goods/services to our organisation.
- Undertake retrospective checks on key existing suppliers to ensure they comply with the requirements of the new supplier process. Where these suppliers fail to do so then engagement shall be required to promote compliance on their part
- We will work with key suppliers to ensure progress is being made towards becoming real living wage employers, as set by the Living Wage Foundation
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2022.
This statement was approved by the Board on the 28th February 2022.