This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Russam’s slavery and human trafficking statement for the financial year ending March 2021.
Modern Slavery encompasses all acts of slavery, servitude, human trafficking and forced labour. Russam has a zero-tolerance approach to any form of Modern Slavery. We are, rather, wholly committed to best practice in terms of acting ethically and with integrity and transparency in all business dealings, and to continuously reviewing our systems and controls to safeguard against any form of modern slavery taking place within the business or our supply chain. Russam’s Board is committed to ensuring that no act that is a form of modern slavery is tolerated within the business and that the Company’s respect for people ethos prevails in all business dealings.
1. Our Policies
In line with our respect for people ethos, employees have the freedom of choice to work for or to leave the company upon reasonable notice. All employees are provided with a clear contract of employment, which complies with UK legislation.
Additionally, in accordance with our Equality, Diversity & Inclusion Policy, all employees are treated in a fair and equal manner and with dignity and respect. We champion diversity and do not tolerate any form of discrimination, victimisation or harassment on any grounds, including but not limited to marital or civil partnership status, sex, gender reassignment, sexual orientation, race (including colour, ethnic and national origin, nationality), age, disability, pregnancy and maternity, having or not having dependents, religious belief or political opinion, trade union activity and offending background.
Russam commits to not taking advantage of lower employment or manufacturing costs in developing countries; adhering to any Government recognised trading sanctions; not trading with those countries which our directors believe are violators of human rights and refusing to work with any client or prospective client which we have reason to consider exploits humans, animals or the environment unfairly.
All applicable laws and industry standards on employee wages, benefits, working hours and minimum age are adhered to in all countries of operation, without any unauthorised deductions. We require any suppliers engaged to observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.
All slavery and human trafficking laws must be complied with including, but not limited to, the Modern Slavery Act 2015.
2. Due diligence processes for modern slavery
As part of our initiative to identify and mitigate risk we follow a four-step cycle which includes:
- Understanding the key human rights issues by way of continuous awareness and training and formulating a human rights policy and communicating to all employees.
- Carrying out an assessment of the impacts of our business, identifying potential risks in the operations / supply chain, including concerned parties that may be affected especially those belonging to vulnerable groups.
- Reviewing the results against our business processes and designing preventative and mitigation measures, implementing, monitoring and reporting to both internal and external stakeholders.
- Ensuring the company grievance / whistle blowing mechanism is accessible and applicable to all staff, with remediation for impacted individuals.
3. Risk Assessments – supplier adherence to our values
We have zero tolerance to child labour, forced labour and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.
In order for a supplier to join our register of approved suppliers they must first complete a supplier questionnaire. They must provide details and evidence requested within all four sections of which one covers Modern Slavery. Our Compliance Team evaluate the details / documents provided and if satisfactory they are approved and added as an approved supplier. Based on the risks identified on the risk register we may conduct an audit or review the suppliers on a regular basis. The company intends to review its agreements and dealings with existing suppliers to ensure compliance with anti-slavery measures.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
4. What we are doing
Russam has in place Grievance / Whistleblowing mechanisms which are available to all employees and candidates. Our Fees are earned solely by invoicing the clients and there is no indebtedness from our services. There are no prohibited fees / fines / deductions or penalties. Our employees enjoy a safe and hygienic workplace and we expect our clients to provide the same for the candidates we place. Our contractors understand their contracts and a member of the Finance / Support team is easily accessible to answer any queries.
5. Training for the Russam team
Russam are expected to comply with all laws, act in accordance with local guidelines and regulations, and to act with integrity and honesty. We undertake regular review of all our policies including our Modern Slavery Policy. We ensure staff have access to any additional information and support they may require with regard to human trafficking, forced labour, servitude and slavery. Further, in line with our continuous improvement philosophy, training requirements are reviewed as an ongoing exercise and provided as required.
6. Measuring Effectiveness
In order to measure our effectiveness in raising awareness and ensuring modern slavery does not take place in any part of our business including our supply chains we regularly review training requirements for all members of staff and we evaluate potential suppliers requiring them to confirm that they understand and comply with the Modern Slavery Act 2015. Employees are also encouraged to make suggestions and comments which are reordered and tracked.
Jason Atkinson, Managing Director, Russam
1st April 2020