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Modern Slavery Policy


Employee’s Responsibilities

Preventing and reporting suspected Modern Slavery is the responsibility of all WMCA employees. Employees are expected to be proactive take any necessary and appropriate steps when procuring goods or services to ensure that modern slavery does not occur. This encompasses assessing any risks to modern slavery and human trafficking.

Employees are required to be aware of the signs of modern slavery and human trafficking and to be vigilant during their day-to-day job roles. Employees must assess the risk of modern slavery when awarding as well as when managing a supplier contract. This involves questioning whether a supplier is based in a high-risk geography (such as conflict-affected zones) or if the contract being awarded is of a high-risk sector (i.e. construction, hospitality and agriculture).

It is the employee’s responsibility to complete the mandatory e-learning courses as part of their induction, this includes courses on Safeguarding Children and Safeguarding Adults which have sections on modern slavery. Employees are also responsible for familiarising themselves with the WMCA Safeguarding Policy, which outlines how to identify and report suspected incidents, and follow the correct procedure as/when necessary.

If you believe or suspect a breach of this policy has occurred, is occurring, or is at risk of taking place, you must report it by speaking to your line manager, the HR Department, a Safeguarding Officer or by following the procedures outlined in the Whistleblowing Policy. Any concerns should be raised as soon as possible, as long as it is safe to do so.

If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, this should be raised with their manager, HR, a Safeguarding Officer or by following the Whistleblowing Policy.

All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Manager's Responsibilities

If a contract manager has any reason to believe that an individual within their supplier workforce is a victim of modern slavery then they must report to either their manager, HR, a Safeguarding Officer or by following the procedure outlined in the Whistleblowing policy.

Management at all levels are responsible for ensuring their direct reports understand and adhere to this policy.

Managers are responsible for seeking out further guidance from HR should they be unsure of any aspects of this policy or the corresponding Modern Slavery Statement.

Human Resources Team’s responsibilities

The Human Resources team has a responsibility to make sure Business Partners are fully knowledgeable on this policy and are taking a proactive approach to ensure their delegates are also aware of the relevant policies and procedures.

Should any modern slavery legislation be updated, it is the responsibility of the HR department to ensure that all relevant policies and procedures are amended, if necessary, to make sure they are fit for purpose in order for the organisation to remain compliant.

HR are to deal with any employee/ manager queries surrounding this policy and relevant legislation accordingly.

If a member of the HR team is made aware of any slavery/ human trafficking suspicions, they are responsible for informing the Designated Safeguarding Lead, or a Nominated Deputy Lead in their absence.

Procurement Team’s responsibilities

Our zero-tolerance approach to modern slavery must be communicated to all suppliers at the outset of our business relationship with them. It is the responsibility of the Procurement team to ensure that the WMCA external supply chain is complaint with the Modern Slavery Act 2015.

Through a self-questionnaire, suppliers are required to confirm their agreement and compliance with this policy. If the supplier meets the criteria for Section 54 for the Modern Slavery Act 2015, they must provide their current Modern Slavery Statement.

At the Procurement team’s discretion, appropriate audits of any supplier will be implemented should a potential risk of modern slavery be identified.

Relationships with suppliers may be terminated if they breach this policy, fail to show their commitment to the Modern Slavery Act 2015 and/or do not consent to appropriate audits taking place.

The Procurement team are responsible for considering modern slavery risks when making procurement decisions. WMCA procurement staff are to seek clarification on abnormally low tenders for amplification as to why this is the case. The tender is to be rejected if the bid is low due to: a breach of the tenderer environmental, social or labour law or illegal State aid is being provided to the Tenderer.

Appointed Safeguarding Officers’ responsibilities

It is the responsibility of the Safeguarding Officers to follow the ‘First Responder’ procedure in line with Section 52 of the Modern Slavery Act 2015, the ‘Duty to Notify’. This includes referring the case to the NRM (National Referral Mechanism) or by submitting an ‘MS1’ form if an adult does not give consent to be referred to the NRM.