This statement sets out First Response Group Ltd.’s (FRG) arrangements 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.

Under the Modern Slavery Act 2015. First Response Group have a legal obligation to publish this statement, and in compliance it can be found on our website..

As part of the manpower services sector, FRG recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

FRG is committed to preventing slavery and human trafficking in its manpower service activities, and to ensuring that its supply chains, albeit predominately United Kingdom based and small, are free from slavery and human trafficking.

Policy Statement

“FRG is committed to upholding the highest standards of ethical conduct and human rights across all aspects of our operations and supply chain. We recognize modern slavery and human trafficking as objectionable violations of human dignity and fundamental freedoms.

As such, we are dedicated to combating these crimes through proactive measures aimed at prevention, detection, and mitigation. We pledge to uphold rigorous policies and procedures to ensure that slavery and human trafficking have no place within our organization or within the organizations we engage with. Our commitment extends to nurturing a culture of awareness and accountability among our employees, suppliers, and partners. We will continually assess and improve our practices to safeguard against the risks of exploitation and to promote ethical and sustainable business practices.

At FRG, we resolve to contribute to the global efforts in eradicating modern slavery and human trafficking.”

Purpose

The purpose of this policy is to demonstrate our commitment to combatting modern slavery and human trafficking in all its forms. It outlines FRG’s stance against slavery and human trafficking, whilst establishing procedures for identifying and addressing such practices within its operations and supply chains and ensures compliance with all relevant legislation and regulations.

In addition, it aims to raise awareness among employees, suppliers, and stakeholders about the importance of eradicating slavery and promoting ethical business practices.

Definition of Modern Slavery and Human Trafficking

Modern slavery is defined as the various forms of exploitation where individuals are coerced, deceived, or forced to perform labour or services against their will.

This can include forced labour, debt bondage, human trafficking, and forced marriage, among others. Human trafficking is defined as the recruitment, transportation, transfer, harbouring, or receipt of persons through the use of force, fraud, or coercion for the purpose of exploitation.

This exploitation can take many forms, including forced labour, sexual exploitation, forced marriage, or the removal of organs.

Legal Framework

The Modern Slavery Act is a piece of legislation, which sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK. Whilst not all of the Act is directly relevant for our business, section 54 entitled ‘Transparency in supply chains’ impacts the corporate sector.

Organisational Structure and Supply Chains

This statement covers the activities of First Response Group Ltd & subsideries.

We are an independent service provider to the infrastructure, corporate construction stadium and events and facilities management sectors. The organisation was founded in June 2007 and develops partnerships with its clients, understanding their service needs and strategy that lead to provision of bespoke solutions to meet expectations.

The organisation’s workforce is employed on permanent and temporary Pay as You Earn (PAYE) contractual basis. All right to work, residency, competence cards/certificates and employment history verification checks are conducted in accordance with the Immigration, Asylum and Nationality Act 2006, British standards, and Quality Management Systems procedure requirements.

The organisation currently operates in the following countries:

  • United Kingdom

Risk Assessment

There are minimum risks related to our services, these are monitored and managed through supplier audits, site welfare visits, supplier PQQ’s. Risks identified will be recorded and reviewed at regular intervals and the Risk Register in our COTO Log updated. These infringements will be reported to the appropriate authority.

Through the supplier/procurement code of conduct FRG will ensure that all suppliers also adhere to the Modern Slavery Act 2015.

Responsibility

The responsibility for the FRG’s anti-slavery initiatives is as follows:

  • Policies: Chief Operating Officer/Board of Directors
  • Investigations/Due Diligence: The Group Compliance Director is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
  • Training: The Group Compliance Director/QSHE Manager are responsible for ensuring that the awareness of slavery and human trafficking risks are communicated throughout the organisation and through the supply chain.

Relevant Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Employee Concerns (Whistleblowing) Policy: The organisation encourages all stakeholders to report any concerns related to the direct activities. This can include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. FRG’s policy is designed to make it easy for workers to make disclosures, without fear of retribution. Employees, customers, or others who have concerns can report any activities associated to slavery and human trafficking by contacting their immediate line manager, Human Resources or confidentially to the COO/HRD via the website.
  • Employee Code of Conduct: FRG’s code of conduct makes it clear to employees the actions and behaviour expected of them when representing the organisation. FRG strives to maintain the highest standards of employee conduct and ethical behaviour.
  • Supplier/Procurement Code of Conduct: FRG 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. As part of the supply chain selection process all potential and existing suppliers are required to complete a supplier questionnaire to assess their suitability as a supplier. Within the supplier questionnaire all suppliers are required to provide evidence of their compliance towards Labour Standards and the Asylum & Immigration Act 2006. This enables the procurement team to identify any potential risks to the quality of the service provision or goods being provided by the supplier and prevent any slavery or human trafficking. All suppliers are audited against the supplier code of conduct.
  • Recruitment Policy: FRG only employs people on a permanent or temporary PAYE contractual basis. Prior to commencement of employment all employees are subject to right to work, residency, competence cards/certificates and employment checks in accordance with the Immigration Asylum and Nationality Act 2006 and British standards Quality Management System procedures. The Recruitment Policy is compliant to all EU and UK legislation, including the minimum wage and therefore is not at risk of slavery and human trafficking.
  • Corporate Social Responsibility Policy: FRG’s Corporate Social Responsibility Policy covers the responsibilities of the Board of Directors and its commitment towards the external Environment, Health & Safety, Workplace, and assurance to the supply chain code of conduct. The Policy is communicated to the whole workforce and forms part of the induction programme.
  • Anti-Bribery/Fraud Policy: FRG’s Anti Bribery Policy aims to prevent any form bribery being committed within the organisation and by any stakeholder(s) associated with its business. We foster a culture of integrity where bribery is unacceptable. This policy is communicated to all employees and forms part of the induction programme.

Due Diligence

The organisation undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • evaluating the modern slavery and human trafficking risks of each new supplier in accordance with the supply chain selection process; conducting supplier audits by our QSHE Manager, which have more focus on personnel management and slavery and human trafficking where general risks are identified;
  • If required, invoke sanctions against suppliers that fail to improve their performance or seriously violate our supplier code of conduct.

Performance Indicators

To comply with the Modern Slavery Act 2015, the organisation:

  • Reviews its existing supply chains by the end of each financial year, this being 31st July to ensure their compliance to the Modern Slavery Act 2015.
  • Awareness training is provided to all Directors, Managers, Supervisors and staff within

FRG as a module within the organisation’s induction, toolbox talks, management development and refresher programmes.

The organisation’s modern slavery awareness training covers:

  • our business’ purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
  • what steps the organisation should take if suppliers or contractors do not implement antislavery policies in high-risk scenarios, including their removal from the FRG’s supply chains.

Awareness-Raising Programme

As well as training staff, the organisation raises awareness of modern slavery issues by maintaining flyers/bulletins and emailing to staff.

The flyers/bulletins explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Board Member Approval

This statement has been approved by FRG’s board of directors, who will review it annually.

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