This anti-slavery policy exists to set out the responsibilities of Roboyo and those who work for us concerning observing and upholding our zero-tolerance position on modern slavery.
It also exists to act as a source of information and guidance for those working for Roboyo. It will help you to recognize and deal with modern slavery issues, as well as understand your responsibilities.
1.1 Regional Scope
This policy applies globally to all employees across the company.
1.2 Definition of Terms
The Modern Slavery Act (MSA) 2015 covers four activities.
1. Slavery – Exercising powers of ownership over a person.
2. Servitude – The obligation to provide services is imposed by the use of coercion.
3. Forced or compulsory labour – Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
4. Human Trafficking – Arranging or facilitating the travel of another person with a view to their exploitation
Modern slavery is a complex and multi-faceted crime. At a basic level, of course, preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense. The MSA 2015 recognizes the important part businesses can and should play in tackling slavery and encourages them to do so.
With this in mind, we need to pay particular attention to our supply chain, any outsourced activities, particularly to jurisdictions that may not have adequate safeguards, cleaning and catering suppliers, and corporate hospitality.
Below we outline the main responsibilities, risks, and procedures related to our anti-slavery policy.
2.1 Responsibilities
Everyone must observe this policy and be aware that turning a blind eye is unacceptable and not an option.
2.1.1 The Company
We will maintain policies and procedures aimed at preventing exploitation and human trafficking and protecting our workforce and reputation. We will be clear about our recruitment policy (see Recruitment) and check our supply chains (see Supply Chains). We will have in place an open and transparent grievance process for all staff. We will seek to raise awareness so that our colleagues know what we are doing to promote appropriate welfare practices. We will make it clear by our policies and our actions that we take our responsibilities to our employees and our clients seriously.
2.1.2 Leadership
Leadership and Managers will listen and be approachable to employees. They will remain alert to indicators of slavery (see Identifying Slavery) and raise the awareness of our colleagues by discussing issues and providing training so that everyone can spot the signs of trafficking and exploitation and know what to do.
2.1.3 Employees
We all have responsibilities under this policy. Whatever your role or level of seniority, you must keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting Slavery). Follow our reporting procedure if a colleague tells you something you think might indicate they or someone else is being exploited or ill-treated. Tell us if you think there is more we can do to prevent people from being exploited.
2.2 Risks
The principal areas of risk we face, related to slavery and human trafficking, include:
We manage these risk areas through the procedures set out in this policy.
2.3 Our Procedures
2.3.1 Supply Chains
We check our supply chain to reduce the potential for slavery and human trafficking. We tell the companies we do business with that we are not prepared to accept any form of exploitation. Our significant supplier contracts, for industries considered high-risk, should contain an anti-slavery clause. This clause will ask suppliers and their employees to commit not to engage in slavery or human trafficking and to diligence their supply chain. We work to account for our supply processes—we know who is providing goods and services to us and we have mechanisms and processes in place to check, including reviewing our significant suppliers’ identity and level of risk in this area and making efforts to confirm their adherence to anti-slavery measures in their businesses.
2.3.2 Talent Acquisition
We only work with approved and reputable recruitment agencies on a preferred supplier basis. To prevent slavery and human trafficking, we thoroughly vet the recruitment agencies before partnering with them. This includes assessing their reputation and requesting assurances that they have conducted appropriate checks on the individuals they are providing. We conduct regular reviews to ensure compliance. We verify that our staff are legally eligible to work in our office locations. We also provide information to all new hires about their statutory rights, including sick pay, holiday pay, and other entitlements. If we suspect that someone is being exploited during our recruitment process, our HR department will follow our reporting procedures (please refer to our Reporting Slavery guidelines).
2.3.3 Identifying Modern Slavery
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim;
This list is not exhaustive.
Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it.
2.3.4 Reporting Slavery
Talking to someone about your concerns may stop someone else from being exploited or abused. If you think that someone is in immediate danger, call the police. Otherwise, you should discuss your concerns with your line manager, a director, or HR, who will decide a course of action and provide any further advice.
Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with your line manager or a Director before taking any further action.
2.3.5 Awareness Training
All employees are responsible for familiarizing themselves with this concept and understanding how to identify indicators of modern slavery. By reading and understanding this policy, all employees will be equipped to act according to our procedures when in doubt.
The company will provide formal training only in situations of increased risk or sensitivity.[JL1]Â
This policy will be regularly reviewed by Roboyo and may be amended at any time or as necessary to align with the company’s evolving needs and industry best practices.
Document Revision History
Approvals