This Modern Slavery Statement sets out the actions taken by Austin Elliot Consultancy Ltd (‘AE’ or ‘the company’) to prevent modern slavery occurring within our operations or supply chains and have been prepared in accordance with section 54(1) of the Modern Slavery Act 2015.
No instances of modern slavery have been identified in our operations or supply chains and the following steps have been taken:
We take our responsibility to prevent modern slavery and trafficking within our supply chain seriously and have written a number of key aims for us to focus attention on. These aims will help to ensure that we are enhancing awareness of modern slavery risks and compliance with our policies and standards within our own business, and that we are carrying out specific due diligence within our supply chains and driving compliance with our standards.
Our anti-modern slavery initiatives are part of our wider social value strategy and sustainability goals that help achieve this purpose. We will not tolerate any form of human rights abuse within our business or supply chains. Our Social Value and Sustainability policy can be found here.
About us
AE provides consultancy services across the Public and Private Sector, neither of which are deemed to be a higher-risk industry for modern slavery practices. Nevertheless, we are mindful of the potential for modern slavery to occur within our operations, and the need to implement robust measures to identify and mitigate against this risk.
Current Procurement Policy
AE ensures that all potential and incumbent suppliers are dealt with professionally, fairly, and ethically and that we uphold the principles of sustainable procurement at all times. Our procedure also complies with UK law and addresses environmental management, health and safety and equality legislation.
Our Code of Practice (‘Code’) applies to all AE employees and sets out the basis of our culture of acting ethically and in accordance with the highest professional standards. The Code makes it clear that all our people have a duty to take the most ethical course of action in any given situation and to report any behaviour which is inconsistent with the principles set out in the Code. All AE employees are required to sign our Code of Practice to confirm that they have read, understood and are in full compliance with the Code.
Any failure to comply with the Code is taken very seriously and can result in disciplinary action against our people up to and including summary termination.
Managing Risk and Adherence to The Act
AE’s standard supplier contract include modern slavery and human trafficking undertakings. We expect our supply chain to respect and comply with all applicable laws, including The Act, and under our standard contracts, AE reserves the right to terminate its arrangements with a supplier which is found to be in breach of The Act.
We encourage people to raise any concerns about potential breaches of our Code of Practice or values, or any other ethical matters, to anybody within the organisation – and they can feel confident that this will be taken seriously and with due sensitivity. This encouragement comes from regular communications from our senior leaders and several of our key policies > Dignity at Work, Equality, Diversity & Inclusion, Anti-harassment & Bullying.
AE considers its main exposure to the risk of modern slavery and human trafficking to exist in the following categories: Hotels, venues, and event services. Building operations (including cleaning, catering and maintenance) and Technology hardware.
With regards to technology hardware, we engage with a few technology companies to source a range of technology hardware items including laptops, monitors, and other computer peripheral. These goods can be manufactured in developing countries, where modern slavery regulation is immature or lacking. Many of these products are procured through suppliers but are consumed by our personnel.
We require our suppliers to provide assurance about their own supplier due diligence efforts and human rights practices. The Supplier Code of Conduct mandates a sub-contracting clause which requires suppliers to confirm that they take necessary steps to maintain visibility over labour rights risks within its entire operation and require subcontractors to comply fully with local laws (including labour law).
In the other categories mentioned, AE is indirectly exposed to potential risk of modern slavery through the recruitment and provision of people by our selected suppliers to carry out these services. The service providers in these sectors, or the sub-contracted labour recruiters further down their supply chain, could find themselves exposed to potential modern slavery risks if targeted by traffickers and gangmasters offering labour.
Our suppliers are obligated to perform various background checks on all recruits supplying services to us, and via our standard supplier contract, we hold the right to audit the supplier at our request to manage the associated modern slavery risks in the supply of services from these categories. We also require the supplier to pay the Living Wage to all of its people involved in the supply of services to us, monitor their working hours and require that they are not engaged using zero-hours contracts.
Social Responsibility and Human Rights
AE is committed to respecting human rights and to acting in a socially responsible manner in our operations. We ensure that our people, offices, and supply chains are not complicit in human rights abuses.
We are committed to continuous improvement in this area will review and monitor and, where necessary, enhance our standards, policies, and procedures, as well as improve the training and communications about The Act.
Declaration
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year. The statement has been approved by the Austin Elliot Partners on 24 April 2024 and signed by Ben Norton, Technical Partner.
Date of approval: 24 May 2024
Ben Norton
Technical Partner
Date: 24 May 2024
