Modern Slavery Policy & Human Trafficking Statement

Slavery and human trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.

The 4C Associates Limited group of companies including its subsidiaries and affiliates (“the Company”) is committed to eradicating modern slavery or human trafficking from its supply chains or in any part of its business and encourages that commitment from its suppliers and clients, and they, in turn, from their supply chains.

We are committed to acting ethically and with integrity in all our business relationships and to taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any business relationship with our Company.

It continues to be a priority for the Company to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout the Company and in its supply chain. This statement highlights the key activities we undertake to combat modern slavery in the Company and supply chain, including how we hold suppliers and clients to account in our contractual relationships with them in a bid to identify and prevent the risk of modern slavery.

We are a growing UK-based Company with an increasingly international footprint, and although our annual turnover falls below the threshold that mandates we publish a modern slavery and human trafficking statement, under section 54(1) of the Modern Slavery Act 2015, we are voluntarily publishing our position and approach to modern slavery to signal our commitment.

 

Due Diligence Processes for Slavery & Human Trafficking

The Company takes a zero tolerance approach to slavery and human trafficking. We expect all those in our supply chain and all contractors to comply with our values.

As part of our initiative to identify and mitigate risk, the Company has in place systems to encourage the reporting of concerns and the protection of whistle blowers and we would encourage anyone in the Company, be they employees, consultants or contractors, who has suspicions about a particular supplier or client to highlight those to the senior leadership team.

We favour using the most reputable supply chain providers and prefer to work with suppliers that are based in jurisdictions that are low-risk for modern slavery, wherever possible, and we expect these entities to have suitable anti-slavery and human trafficking policies and processes of the kind that we would observe.

Where we have had cause to provide services ourselves overseas in countries that could rightly or wrongly have a reputation for being modern slavery or human trafficking blackspots, we have engaged directly with individuals and companies on economically favourable terms to ensure that we know that these individuals are fairly remunerated. This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy notices on the other websites you visit.

Training

The management team is responsible for compliance within its respective departments and in their supplier relationships and have been trained accordingly.

There is a Company induction where our policies, procedures and expectations, including this modern slavery and human trafficking statement, are highlighted.

 

Our Effectiveness in Combatting Slavery & Human Trafficking

The Company uses the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Use of labour monitoring, right to work documentation and payroll audits.
  • Maintenance of a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations.
  • Regularly review of supply chain policies, codes of conduct and our working practices
    to show commitment.

The Company expects the suppliers and clients with which it works to have included modern slavery clauses in their contracts with it, backed up by modern slavery statements/policies and, where they have not, pushes for inclusion of these commitments. Our public sector clients recognise their obligations to tackle modern slavery, in accordance with government guidance, and customarily include these clauses in their agreements with us, as well as including these obligations in their contracts and tender documents for public procurement within their supply chains. Many clients, particularly those in the public sector, encourage payment of individuals at the living wage, rather than minimum wage, within their tenders and supply chains.

 

Reporting Suspicions of Slavery

While the Company encourages best practice, it is conscious that its employees and contractors are the ones who may be closest to a particular client or supplier and knowledgeable about particular practices. With that in mind, you can report any suspicions of slavery either through the Company’s Ethics Policy or externally to the Modern Slavery and Exploitation Helpline using the following contact points:

Signed by
Simon Terry,
Chief Executive Officer