MODERN SLAVERY STATEMENT
Modern Slavery and Human Trafficking Statement 2022
The information in this statement, which is signed by our Chief Executive Officer, details the policies, processes and actions Indaver has taken to mitigate the risk of modern slavery and human trafficking in our supply chains and any part of our own business. It covers the activities of all businesses in all jurisdictions within the Indaver Group of companies and is Indaver’s Modern Slavery Statement for the financial year ended 31 December 2021, required under the provisions of the Modern Slavery Act 2015 (the “Act”).
Slavery is illegal everywhere in the world, but despite that, there are currently an estimated 40.3 million people in modern slavery or victims of human trafficking across the globe. Out of the millions of people trapped in modern slavery, 16 million people are exploited by the private sector, so it is paramount that businesses take action to end these abhorrent practices. At Indaver, we are committed to playing our role by ensuring that through our management and operations we have the systems, policies and processes in place to identify any potential instances of exploitation and, if found, eradicate modern slavery in all its forms from our business and supply chain. We are taking the appropriate steps to ensure that everyone who works for Indaver benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.
Indaver is a purpose-led organisation that exists to create better outcomes for all our stakeholders. This includes our people, clients, customers, suppliers and partners, as well as investors and civil society organisations.
What matters to them | How we engaged Our people
- Flexible working
- Learning and development opportunities leading to career progression
- Fair pay and benefits as a reward for performance
- Two-way communication and feedback
- People survey
- Regular all-employee communications
- Employee director participation in Board discussions
- Employee focus groups and network groups
Clients and customers
- High-quality service delivery
- Delivery of transformation projects within agreed timeframes
- Rapid response to support pandemic planning
- Client meetings and surveys
- Regular meetings with government and annual review with Cabinet Office
- Created a senior client partner programme giving an experienced, single point of contact for key clients and customers
Suppliers and partners
- Payments made within agreed payment terms
- Clear and fair procurement process
- Building lasting commercial relationships
- Working inclusively with all types of business
- Supplier meetings throughout source to procure process
- Regular reviews with suppliers
- Supplier questionnaires
- Financial reporting
- Access to the Board and senior management
- Regular communication
- Financial and other reports and trading updates
- Regular investor programme and feedback throughout the year
- Government roundtable for shareholders
- Remuneration consultation
- Social mobility, youth skills and jobs
- Digital inclusion
- Diversity and inclusion
- Climate change
- Business ethics
- Memberships of non-governmental organisations
- Charitable and community partnerships
We also recognise that there are risks in relation to modern slavery and human trafficking outside of our core stakeholder groups. That is why we work closely with other partners such as recruitment agencies and trade unions to mitigate those risks.
Annually, we benchmark ourselves against external indices to ensure our approach to responsible business is appropriate for our organisation and in line with industry best practice. As a responsible business, Indaver recognises the importance of independent non-financial reporting and memberships which demonstrate commitment to our purpose and values. We actively participate in an independent assessment of our approach to labour and human rights, which includes our response to modern slavery. We partner with organisations which share our values and support responsible business practice, including modern slavery, activities.
Our policies The following company policies support us in mitigating the risks of modern slavery in our business and supply chain. They apply to all Indaver companies and are available to all colleagues via our intranet site and website. The policies are managed by relevant functional heads such as HR, Procurement and Responsible Business, and are imbedded in our company-wide risk management framework. Code of Conduct (The Code) describes what we must do and how we must behave to ensure we have the trust of all our stakeholders. And we will create better outcomes in the right way, not at any cost, in line with our purpose and values. The Code builds on these foundations and applies to everyone who works at, or with, Indaver. It summarises in one place elements of our key policies, and the standards and procedures which support them.
Speak Up Policy
sets out our commitments to speaking up about serious concerns, detailing how any person working at or with Indaver, including those employed in our supply chain, can raise concerns or ‘whistle blow’ and the channels available to do so confidentially, responsibly and effectively and without fear of repercussions. This policy is supported by a fully anonymised online portal which is accessible to all stakeholders, and includes geographically appropriate telephone numbers, run by an independent third party on behalf of Indaver. We also run a related ‘Disclosure and Whistleblowing’ compliance training programme for identified colleagues operating in regulated areas of Indaver.
sets out the principles of how we will conduct business in an open, honest and transparent manner, and the behaviours and practices we expect of our suppliers and partners. This includes specific reference to our expectations for our suppliers to never use or support practices that inhibit the development of children, not hold an individual nor group in slavery or servitude, not use any form of involuntary labour, nor traffic individuals or groups for the purpose of labour exploitation in line with the Modern Slavery Act. We expect all our suppliers to report any issues of compliance with our charter to us within five working days, or any shorter period required by regulation. We expect all our suppliers’ colleagues or contractors to report any breaches through their own grievance mechanism, or directly to Indaver.
Diversity and Inclusion Policy
ensures that we foster a fair and inclusive workplace, where our people are valued, their differences are respected, and discrimination is eliminated. Our policy is supported by a mandatory Diversity and Inclusion training module for all colleagues that needs to be taken annually
sets out what our suppliers should expect from us when we buy goods and services and the requirements that must be met by every one of our businesses, in every country where we operate, when doing so. This includes operating responsible business procurement practices with clear and fair procurement processes and paying promptly in accordance with payment terms.
Human Rights Policy
ensures appropriate procedures are in place to mitigate the risk of potential breaches of international human rights standards, including the United Nations’ Universal Declaration of Human Rights (UDHR), the International Labour Organisation (ILO) core conventions on Labour Rights, and the Modern Slavery Act. The Human Rights policy is referenced within our mandatory Diversity and Inclusion training module.
sets out our commitment to prioritise and create working environments that protect, support, and promote the wellbeing of all our colleagues, managing any factors that may cause negative emotional, psychological, physical, or social impacts. We expect everyone to have the necessary training and awareness to protect the wellbeing of all our colleagues with working conditions that make our people feel happy and healthy.
sets out our commitment to safeguarding our colleagues, and any other adults at risk or children who come into contact with us during work related activities. Safeguarding relates to promoting the welfare of adults at risk or children and protecting them from harm. We are committed to providing the necessary training to our colleagues to do this, fulfilling our legal and regulatory safeguarding requirements, and providing a safe, efficient, confidential and supportive process for reporting and managing any safeguarding concerns or issues.
All contract risks, including potential human rights, modern slavery and human trafficking risks, are managed and monitored through the contract lifecycle, as per our Corporate Risk Management Framework. This requires rigorous assessment at contract, business unit and divisional level and review at executive level. We identified two areas of priority risks in relation to modern slavery and human trafficking, one in relation to our colleagues, and another in relation to our suppliers.
At a minimum, we expect both ourselves and our suppliers to comply with all applicable local laws and regulations, providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically, and using environmentally responsible practices where practicable. Suppliers’ compliance with the Supplier Charter is managed through our rigorous supplier onboarding due diligence process for all new suppliers and an ongoing annual risk questionnaire for Tier 1 and high-risk suppliers.
The questionnaire covers the following areas:
- human trafficking and slavery
- health and safety
- the environment
- data protection
- information security and bribery
We prioritise suppliers that can demonstrate commitment to upholding responsible business practices. Our tendering process includes an increased weighting for those suppliers that perform well against our required criteria related to modern slavery, environment, diversity and inclusion. This takes the form of a mandatory corporate social responsibility questionnaire which includes a statement supported by evidence of a supplier’s commitment to addressing human rights and modern slavery which is reviewed for completeness and compliance.