Modern Slavery Policy

Last Updated: 22/08/2023

Our Commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude and compulsory labour and human trafficking. ArbCulture Ltd is committed to acting ethically and preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

As part of the Agricultural sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Steps for the prevention of modern slavery

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.

  •  Anti-Slavery Policy: We share the Anti-Slavery Policy with all our team members to ensure they understand their responsibilities under the Modern Slavery Act and how to raise any concerns.

  •  Whistleblowing: We encourage all our team members to report any concerns related to the direct activities, or supply chains of our organisation. The Whistleblowing Policy in our employee Handbook explains how a team member can raise concerns in confidence without any fear of retaliation.

  •  Code Of Conduct: We explain the standards of conduct as we expect of all our team with the aim to explain our expectation of the highest standards of employee conduct and ethical behaviour both within our business and when acting on behalf of ArbCulture Ltd with contractors and suppliers.

  •  Recruitment: ArbCulture Ltd only engages reputable recruitment companies to support its activities. Prior to engaging the services of a recruitment company, ArbCulture Ltd carefully reviews the recruitment practices and terms and conditions of engagement to ensure they will uphold the same high standards ArbCulture Ltd maintains for all direct recruitment.

  • Procurement Policy: We are committed to ensuring that our subcontractors and suppliers adhere to the highest standards of ethics. We require suppliers to demonstrate that they provide safe working conditions and act ethically and within the law in their use of labour.

Due Diligence

We undertake due diligence when considering engaging the services of new suppliers. We also conduct periodic reviews of our existing suppliers.

These due diligence activities include:

  • Mapping the supply chain broadly to determine activities with potentially higher risks of modern slavery or human trafficking.

  • Including modern slavery and human trafficking clauses in contractual documentation when engaging suppliers and establishing subcontractor relationships.

  • Evaluating the modern slavery and human trafficking risks of each new supplier.

Continuous Improvement

ArbCulture Ltd is committed to continual improvement and the review of current standards. This includes updating practices based on new legislation, industry guidance and best practice.

Looking ahead, ArbCulture Ltd will be focused on:

  • Creating new supplier guidance which will help to provide additional clarity and process to identify any potential risks regarding modern slavery and human trafficking.

  • Coaching and training suppliers to raise awareness of modern slavery and improve standards across all organisations with which we are engaged.

  • Introducing new control measures and governance as the organisation continues to grow and expand in connections and network footprint.

Training

ArbCulture Ltd requires all team members to complete essential Compliance and Health & Safety training. We plan on introducing an e-Learning module on Modern Slavery.

This e-Learning covers:

  • The basic principles of the modern Slavery Act 2015.

  • How to flag up potential slavery or human trafficking concerns to relevant people within our business without any fear of victimisation.

  • What external help is available including the Modern Slavery Helpline, Gangmasters and Labour

  • Abuse Authority and the “Stronger together” initiative.

Applicable Organisations

This Modern Slavery statement applies to ArbCulture Limited. All ArbCulture Ltd Staff, sub-contractors and suppliers.

Anti-Slavery Policy Introduction

  • ArbCulture Ltd has a zero-tolerance approach to Modern Slavery and is committed to providing a working environment and supply chain free from exploitation.

  • We will always act ethically and with integrity in all our business dealings and relationships.

This policy does not form part of our employment contracts and we may amend it at any time.

Definition of Modern Slavery

  • Modern Slavery takes various forms including slavery, servitude, forced and compulsory labour and human trafficking.

  • The Modern Slavery Act 2015 requires that commercial organisations work to ensure that slavery is not taking place within their organisations or supply chains.

Responsibility for the policy

  • ArbCulture Ltd has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those employed by, or engaged on behalf of, ArbCulture Ltd comply with it.

  • ArbCulture Ltd has primary and day-to-day responsibility for implementing this policy, monitoring and auditing business practices and dealing with any queries or concerns related to this policy.

  • All managers, at all levels, are responsible for ensuring those working in their teams understand their obligations and have adequate training to identify issues of modern slavery in supply chains.

Policy compliance

  • You must ensure you have read, always understand and comply with this policy. If you have questions or require support, please raise this with your manager in the first instance.

  • Operating with the highest ethical standards is a team effort and we must work together to prevent, detect and report Modern Slavery in any part of our business operations or supply chains.

  • You must avoid any activity that might lead to or be considered to be a breach of this policy.

  • If you suspect Modern Slavery breaches in any part of our business or supply chains, you must

    notify the relevant Company contact in accordance with our Whistle Blowing Policy without delay.

  • If you are concerned or unsure about whether the treatment of labour or working conditions in any tier of our supply chains constitutes any of the various forms of Modern Slavery, raise

    you're concerns with your manager or a Company Director.

Communication and Training of this policy

  • Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced at regular intervals thereafter.

  • Training and policy updates will be provided via established communication channels. This will form part of the induction process for all new members of our team.

How we respond to breaches of this policy

  • Breaches of this policy will be dealt with in accordance with our disciplinary procedure.

  • Any team member who reports a concern or who participates in good faith in any investigation

    must not suffer any form of retaliation or victimisation as a result. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our disciplinary procedure.

  • Anyone found to have retaliated against or victimised someone linked to raising Modern Slavery concerns will be subject to disciplinary action under our disciplinary procedure.

  • We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy or fail to provide sufficient evidence of their compliance with Modern Slavery Act 2015 requirements.

What to do if you experience detrimental treatment

  • If you experience detrimental treatment connected with raising a Modern Slavery concern, you may wish to raise this with your manager.

  • If you do not feel that informal steps are appropriate, or they have been unsuccessful, you should raise the matter formally under our grievance procedure.

  • If we consider that there is sufficient evidence to suggest misconduct, we will consider the appropriate action(s) to take. If the person accused is a colleague, this may include invoking our disciplinary procedure. Whether or not your complaint is upheld, we will sensitively consider how best to manage any ongoing working relationship between you and the person concerned.

If you have any questions about this Modern Slavery Policy, please contact us at info@arbculture.uk.