Anti-Slavery Policy

The Modern Slavery Act (MSA 2015) consolidates offences relating

to trafficking and slavery.

The Board of Wardcon Limited Slavery and Human Trafficking Statement 2023-2024

This statement sets out the steps that the Wardcon Ltd has taken during the financial year ending 31 March 2023 to ensure, as far as possible, that modern slavery is not taking place within its business or its supply chains. Wardcon Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically, transparently and with integrity in all our business dealings and relationships. To our knowledge, there have been no instances of modern slavery during 2023—24.

Our structure and business

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Our activity

SUPPLY CHAIN

Wardcon’s standard terms and conditions for the purchase of goods and services require suppliers to comply with the Modern Slavery Act 2015 and allow for termination in the event of non-compliance. The overall risk of modern slavery in our supply chain remains low, since most of our procurement is undertaken through framework agreements (such as the Crown Commercial Service and through recognised Supplier Management Procurements), which have their own robust contract compliance and supplier management processes. With regards to retail, our trading activities do not generally involve high risk activities such as production and/or sourcing outside of the UK or the EU.  All suppliers of products to Wardcon’s trading subsidiary must self-certify against a range of ethical standards, which explicitly includes modern slavery in supply chains, and we request annual updates of their supporting certification.

In April 2023 our CEO approved our 2023 to 2028 Procurement Strategy which sets out the strategic approach to procurement for both Wardcon Ltd and iDevelop. We will ensure that our direct suppliers, and where possible their sub-contractors, are absolutely committed to preventing Slavery within their own activities and through their supply chain which includes manufacturers and producers

RECRUITMENT AND OUR PEOPLE

We have a variety of policies and procedures in place to ensure compliance with UK employment law, and periodic internal audit reviews provide assurance on the operation of these policies. Our Human Resources support team manage recruitment activities with recruiting managers and only use reputable employment agencies and job boards to source candidates. We carry out appropriate background checks including Right to Work and Disclosure and Barring Service checks for all fixed term and permanent appointments.

Regular meetings between management and union representatives provide structured opportunities to discuss issues affecting staff. Members of staff are also encouraged to provide feedback through an annual Staff Survey, the results of which feed into operational planning and decision-making.

POLICIES

Wardcon Ltd maintains a suite of established formal policies including Anti-Slavery, Safeguarding, Ethical and Environmental Trading, Third Party Engagement, Procurement, Recruitment, and Whistleblowing. Policies are regularly reviewed and ratified by our Executive Board/trustees as applicable. The policies are communicated to all staff to inform them of the standards to which both Wardcon Ltd staff and suppliers must adhere, and the mechanisms available to staff and suppliers to report issues/concerns. These mechanisms include the provision of a confidential, independent whistleblowing hotline, and a dedicated safeguarding email inbox.

During 2022—23, we revised our Safeguarding Policy to incorporate a greater focus on our international work, introduce a code of practice, and to detail best practice in relation to managing disclosures. The policy is available in seven languages and an easy-read format.

WORK OUTSIDE OF THE UK

Wardcon Ltd adheres to local laws in the countries we work in. Acknowledging that working overseas in an area of potential risk (given the different regulatory and legal environment in many countries), Wardcon do commissioned an advisory review of Finance and HR controls in operation at the proposed sites of work. We have used such findings from these reviews to further refine our human resources practices, and to help embed effective working structures between the UK and client offices going forward.

Our future

Wardcon Ltd is committed to the continuing evaluation and improvement of our systems and processes. Some of the planned activity for 2023-24 which will contribute towards our anti-slavery commitments includes:

  • A sustained focus on safeguarding awareness, including training which contains specific modern slavery elements (for staff in relevant front-facing and international roles), and the implementation of a Mandatory Training Policy to drive compliance with training completion, including safeguarding training.
  • Refinement of an international safeguarding framework to enhance governance measures to mitigate risk both internally within Wardcon Ltd and in our work with partner agencies.
  •  April 2023 saw the Safeguarding, Security and Logistics works be provided with oversight from Wardcon’s Head of Safeguarding. schemes, such as planting trees.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2023. It has been approved by Wardcon’s Board and signed on their behalf by:

Contact us

Questions, comments, and requests regarding this policy should be emailed to; info@wardcon.net, and please use the subject heading: Anti-slavery