Trafficking Policy

Modern slavery is a criminal offence under the Modern Slavery Act 2015 UK and Criminal Law (Human Trafficking) Act 2008 Ireland.  The Act requires commercial organisations of a certain scale and which are carrying on business or part of their business in the UK to disclose the steps which they have taken (if any) to ensure their business and supply chains are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking).

This disclosure takes the form of an "anti-slavery and human trafficking statement", which must be published each financial year on the organisation's website within six months of the organisation's financial year end.  Of particular importance is the extra-territorial reach of the Act: it applies not only to UK organisations, but also to businesses that are incorporated and headquartered outside the UK but that conduct business within the UK. As part of Green Circle’s due diligence we are dedicated to the prevention of Modern Slavery and Human Trafficking within our business and throughout our supply chain. To demonstrate our commitment to this and in relation to our suppliers and sub-contractors we shall: 

  • Identify, monitor and assess those areas of our business and supply chain most at risk from Modern Slavery and implement initiatives to enhance risk management effectiveness. 
  • Engage with our Supply Chain at the outset of our relationship to convey the importance of this policy as any noncompliance found may result in the termination of a contract. 
  • As part of our Supplier on boarding process they will be required to commit to ensuring a zero tolerance approach to Modern Slavery.

In relation to recruitment, Green Circle will ensure:

  • The recruitment policy is compliant with the Modern Slavery & Human Trafficking guidelines.  The Human Resource Department will be responsible for screening & vetting of new hirers. They will also be responsible for monitoring and auditing right to work visas. 

Allegations Of Anti-Slavery And Human Trafficking

  • All employees have a responsibility to report any concerns relating to possible slavery and human trafficking in the work place or in the workplace of a supplier/sub-contractor.  Anyone who has concerns regarding acts or potential acts of anti-slavery or human trafficking should speak confidentially to their Compliance Advisor in the first instance, or if this is not possible, they should contact a Director.  Alternatively, concerns can be reported anonymously to the Anti Human Trafficking Unit at the  Department of Justice and Equality.  Further information about reporting concerns is available in the organisation's Whistleblowing Policy.

  • Any employee suspected of, or found to have committed an act of slavery or human trafficking will be reported to the Anti Human Trafficking Unit at the Department of Justice and Equality and may be subject to an investigation and as appropriate, disciplinary action under the Disciplinary and Dismissal Procedure which may result in summary dismissal.

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