Modern Slavery Policy

Change history

Version numberDate of releasePolicy ownerAuthorised by
1.108 September 2023Naomi da Silva, Head of Business AssuranceBoard of Trustees

Policy statement

Modern slavery is a crime and a violation of fundamental human rights under the Modern Slavery Act 2015 (‘the Act’). It takes various forms such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Central YMCA procures a wide range of goods, services and works which are sourced from both national and international suppliers.

As a charity, we are committed to ethical business practices in line with our values and recognise that we have a responsibility to take a robust approach to our own practices and those in our supply chains, to protect some of the most vulnerable people in society. We are committed to a zero-tolerance policy in relation to modern slavery and human trafficking.

This policy lays out the steps taken by Central YMCA (‘The Charity’) to ensure that there is no slavery or human trafficking taking place in the organisation or in our supply chains.

Our slavery and human trafficking statement and a link to this policy will be made available on the Charity’s website.

Scope 

This policy applies to the Charity’s own practices and the practices of its external suppliers and partners.

Related Legislation, Compliance and Guidance 

Responsibilities

Board of Trustees
Overall responsibility for the policies and procedures that govern the work at Central YMCA.

Chief Executive
Overall responsibility for ensuring Central YMCA’s resources are used effectively and appropriately.

Policy Owner
Responsible for ensuring the policy aligns with regulatory requirements and best practice and also reflects our charitable ethos and commitment to equality and diversity.

All Line Managers
Responsible for ensuring all employees are aware of and follow this policy.

All Employees and Volunteers
To follow policies and procedures, promoting best practice throughout the organisation.

 

Policy

1. Definition

Modern slavery is an umbrella term for all forms of slavery, servitude, forced or compulsory labour and human trafficking. The Modern Slavery Act 2015 (‘the Act’) combats modern slavery and consolidates previous offences relating to trafficking and slavery

2. Objectives

To support awareness on our responsibilities under the Act and inform staff of the appropriate action to take if they suspect a case of slavery or human trafficking

To mitigate the risk of modern slavery in our supply chains, supporting customer confidence and minimising reputational risk

To help ensure staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK

To ensure that consideration of the modern slavery risks and prevention are added to the Charity’s policy review process as an employer and procurer of goods and services

To ensure that the Charity’s procurement strategies and contract terms and conditions include references to modern slavery and human trafficking

To support and embed a zero-tolerance approach towards modern slavery

To ensure appropriate training is provided to staff on modern slavery and ethical employment practices

3. Aims

Central YMCA is committed to the principles of the Act and the abolition of modern slavery and human trafficking.

As an equal opportunities’ employer, we are committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

We have zero tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our activities and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within the Charity or in any of our supply chains. The same standards are expected from our contractors, suppliers or other partners. We will seek to include in our contracts specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

4. Procurement of goods and services

https://www.unglobalcompact.org.uk/the-ten-principles/

Central YMCA procures a wide range of goods, services and works to deliver the Charity’s activities. This includes the purchase of office and cleaning supplies, professional services, IT equipment and services, and facilities works, goods and services. Each of these hold risks in relation to modern slavery and human trafficking.

In line with the Charity’s procurement policy, we are committed to carrying out procurement activities in an environmentally, socially, ethically and economically responsible manner and to entering into agreements, and contracts, with suppliers that share and adhere to this vision.

The Charity aligns its practices with the 10 principles of the United Nation’s Global Compact and expects the following behaviours from its suppliers:

  • Social compliance, for example no use of forced or under aged labour, the provision of suitable working conditions and fair treatment of workers
  • Ethical compliance and economic development, for example acting with integrity, compliance with laws and regulations, and support of fair trade
  • Environmental compliance, for example avoidance of environmental harm and taking actions to reduce environmental impact

Any contract terms and conditions with suppliers must include references to modern slavery and human trafficking

5. Due Diligence

Due diligence must be undertaken on any new supplier, in line with the Charity’s Procurement Policy, to ensure compliance with the Act. Suppliers will be asked to provide evidence of their compliance with the Act, to ensure they act ethically and within the law.

The Government’s Modern Slavery Statement Registry will be reviewed to check for the publication of Modern Slavery Statements and where not published, suppliers will be asked to share their statement, policy or approach to this.

The Charity will not support or deal with any business knowingly involved in slavery or human trafficking.

6.Recruitment

During the hiring process we undertake checks to ensure all those employed by the Charity have the legal right to live and work within the UK.

All candidates are required to provide documentary evidence of their right to work in the UK and their identity. Evidence should be as prescribed by UK Visas and Immigration and the Disclosure and Barring Service, and a list of suitable documents is provided by the Charity’s HR department.

Where recruitment is outsourced to a third-party agency, only specified, reputable employment agencies are used. The practices of any new agency are verified before accepting workers from that agency; with the same checks required to be undertaken.

We will also verify that the minimum wage requirements of any agency staff are met. This also relates to the outsourcing of services, for example where agency staff are used for the cleaning of premises   

7. Training

Procedures are in place to ensure that this policy is understood and communicated to all levels of the charity.

The Charity will provide training to managers and other staff as appropriate to help improve awareness of modern slavery, help them to identify risks and ensure they understand their responsibilities.

8. Responding to an incident of modern slavery

If anyone is concerned they may have come across an instance of modern slavery they should contact the Head of Business Assurance who will contact the Modern Slavery Helpline for information and guidance on what to do next.

If we identify a potential victim of modern slavery they can be referred to the National Referral Mechanism to be formally identified as a victim of modern slavery and offered government-funded support. Referral for potential adult victims is by consent. If a case of modern slavery is identified in the UK, it should be reported to the police immediately

If the incident relates to one of the Charity’s suppliers, guidance should be shared in relation to the implementation of anti-slavery policies. If, after receiving support, the supplier is not taking the issue seriously, we will terminate our commercial relationship with the supplier

External stakeholders can report any concerns of modern slavery via the Charity’s Feedback and Complaints Policy.

9. Slavery and human trafficking statement

The Charity volunteers to publish a slavery and human trafficking statement annually. Publishing an annual statement demonstrates transparency and progress against prior years.

The statement will be reviewed annually shortly after the Year End, will be approved by the Board of Trustees and published on the Charity’s website.

The statement should provide the steps taken to address and remedy human trafficking within the organisation and our supply chain and should include information on the following:

  • The Charity’s structure, business and supply chains
  • Our policies in relation to slavery and human trafficking
  • Any due diligence processes in relation to slavery and human trafficking in the Charity and our supply chains
  • The parts of the Charity and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to assess and manage that risk
  • The effectiveness in ensuring that slavery and human trafficking is not taking place in the Charity’s business or supply chains, measured against such performance indicators as it considers appropriate
  • Any training and capacity building about slavery and human trafficking available to staff

10. Appendices

Our Modern Slavery Statement

Central YMCA is a national charity that advances the education, health and wellbeing of our communities. Our vision is to enable everyone to achieve their potential, live a fulfilled life and contribute positively to society. We provide health and wellbeing, education and training programmes nationally through locations across England. We also deliver products and services internationally through our awarding organisation, YMCA Awards.

We believe in breaking down barriers through our value of Equity, being Creative in our approach to tackle today’s challenges, being Brave in our decisions, and Nurturing everyone we work with to ensure they succeed.

Central YMCA procures a wide range of goods, services and works which are sourced from both national and international suppliers. This includes the purchase of office and cleaning supplies, professional services, IT equipment and services, and facilities works, goods and services. Each of these hold risks in relation to modern slavery and human trafficking.

As a charity, we are committed to ethical business practices in line with our values and recognise that we have a responsibility to take a robust approach to our own practices and those in our supply chains. We are committed to a zero-tolerance policy in relation to modern slavery and human trafficking.

The Charity will not support or deal with any business knowingly involved in modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains.

The Charity is committed to tackling modern slavery issues as they may arise in respect of recruitment procedures and will act in compliance with legal requirements under the Modern Slavery Act 2015 (‘the Act’). The Charity will only work with employment agencies which likewise comply with the Act. We will apply selection and recruitment practices that help identify and tackle modern slavery.

The Charity encourages all staff, members, learners and other stakeholders to report any concerns relating to its direct activities and in respect of its supply chains where they believe there is or maybe a risk of non-compliance with this policy statement.

Further activities will be undertaken in the future to adopt processes which reflect the Charity’s commitment to addressing modern slavery in our supply chains. This includes:

  • Training to be provided to staff to improve awareness, help them identify risks of modern slavery and carry out their responsibilities.
  • A review of the Charity’s procurement processes and contract documentation to ensure the requirements of this policy and related legislation are incorporated as appropriate
  • The implementation and enforcement of effective systems and controls and development of associated performance measures

This policy statement is reviewed by the Charity’s Board of Trustees annually.

Some processes are for internal use only.