Introduction

This policy sets out PCF Training & Consultancy Solutions Ltd actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

PCF Training & Consultancy Solutions Ltd recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This policy covers the activities of PCF Training & Consultancy Solutions Ltd:

PCF Training & Consultancy Solutions Ltd provides consultancy services, this includes Employability training, community learning and Corporate Social Responsibility advisors to the relevant industry standards. The supply chain into PCF Training & Consultancy Solutions Ltd would-be associate trainers and advisors.

The organisation currently operates in the following countries: PCF Training & Consultancy Solutions Ltd operates in the UK and provides employability training and consultancy services.

Responsibility for the organisation's anti-slavery initiatives is as follows

Policies: The Directors of PCF Training & Consultancy Solutions Ltd are responsible for reviewing policies and the process by which they were developed.

Risk assessments: The process and organisational responsibility for human rights and modern slavery risk analysis is undertaken annually, unless a situation has occurred and in the unlikely event this happens then the process is accelerated with immediate effect.

Investigations/due diligence: Members of the Board of Directors have the responsibility for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

The organisation encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

*mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.

*evaluating the modern slavery and human trafficking risks of each new supplier.

*reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.

*conducting supplier audits or assessments through completed supplier forms which have a greater degree of focus on slavery and human trafficking where general risks are identified.

*taking steps to improve substandard suppliers' practices, including providing advice to suppliers through and requiring them to implement action plans.

*participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking.

*Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship. 

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) considering the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

* developing a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and

*  reviewing its existing supply chains annually expected to be completed by year end, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires all staff/supply chain managers within the organisation to complete training on modern slavery.

The organisation's modern slavery training covers:

• our business's purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below the country's national minimum wage, or the provision of products by an unrealistic deadline.
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
• how to identify the signs of slavery and human trafficking.
• what initial steps should be taken if slavery or human trafficking is suspected.
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative.
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Board approval

This statement has been approved by the organisation's board of directors, who will review and update it annually