This statement sets out CAM’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
As part of the Facilities Service Industry, CAM recognizes that it has a responsibility to take a robust approach to slavery and human trafficking.
CAM is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
The following is the process by which the company assesses whether or not particular activities are high risk in relation to slavery or human trafficking:
• Stakeholders are identified and educated to follow the risk process when procuring services or goods.
• Contractors and suppliers are identified and educated to follow the risk process when supplying services or goods.
CAM undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.
Responsibility for CAM anti-slavery initiatives is as follows:
Implementation of Policy: The Board of Directors will draft and implement the policies and ensure they are reviewed at a minimum of once a year. The Managing Director (MD) has responsibility for ensuring adherence to the policies.
Planning and Organisation: Risk assessments will be put in place by the Human Resources Department, who will have ownership of the process and review.
Measuring Performance: Investigations into the potential of modern slavery will be conducted by the HR Department and findings will be reviewed by the MD personally.
Review & Audit: This Policy and its constituent parts therein will be subject to external audit under the ISO provisions, and reviewed by the HR Department and the MD on an annual basis. This process will be undertaken so as to ensure continued relevance, and active participation on the behalf of the Company’s employees, stakeholders and contractors/suppliers.
Relevant Policies: CAM operates the following policies that describe its approach to the identification of modern slavery risks and highlight the steps to be taken to prevent slavery and human trafficking in its operations:
• Whistleblowing policy
CAM encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of CAM. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. CAM’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
• Employee code of conduct
CAM’s contracts of employment makes clear to employees the actions and behaviour expected of them when representing CAM. CAM strives to maintain the highest standards of employee conduct and ethical behaviour when undertaking its activities and managing its supply chain.
• Supplier code of conduct
CAM Is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. CAM works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of CAM’s supplier code of conduct will lead to the termination of the business relationship.
• Anti-Bribery and corruption policy
CAM is committed to the highest standards of ethical conduct and integrity in its business activities. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.
Training & Awareness programme
The expectation of suppliers & employees code of conduct will be covered at induction. Refreshers will be provided annually by all senior line managers.
CAM will seek to train its HR personnel on the matters of modern slavery wherever reasonable to do so. The focus of the training will be provided in association with the Stronger Together initiative. As well as training staff, CAM has raised awareness of modern slavery issues by circulating a series of emails to staff.
The emails explain to staff:
• The basic principles of the Modern Slavery Act 2015
• How employers can identify and prevent slavery and human trafficking
• What employees can do to be alert to potential slavery or human trafficking issues relevant to CAM’s undertakings
• Highlight external help available: such as the Modern Slavery helpline
Monitoring equal opportunity
CAM’s Human Resources Department, with assistance from the Safety Department, will regularly monitor the effects of lone working and operational adherence to the policy. If anomalies are identified, CAM will address them as soon as reasonably practicable. Where adjustments to the policy are required, they will be implemented across all operational activities within the Company. All adjustments adopted will subsequently be added to the Standard Operating Procedures as necessary.
This statement has been approved by the Managing Director who will review and update it annually.