Modern Slavery & Human Trafficking Act

 

Document Ref: ML-MSHTA | Version: 1.0 | Last Updated & Approved: 22/12/2022 | Review Period: 12 months | Next Review: 22/12/2023


Table of Contents

  • Introduction
  • Organisational Structure
  • Our Supply Chain
  • Policies
  • Due Diligence
  • Risk and Compliance
  • Effectivness

Introduction

We are serious about our brand because it’s part of our identity, and so is our commitment to corporate social responsibility. We believe transparency is the best way we can assure the public that we are doing our best as an ethical corporate citizen.

We’re committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy is reflected in our commitment to use only legal and ethical business practices and to implement and enforce effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

This Modern Slavery and Human Trafficking Statement is a response to Section 55(1), Part 6 of the Modern Slavery Act 2015.

Main Layer Ltd (‘the Company’, ‘we’, ‘us’, and ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Main Layer Ltd has business operations in the United Kingdom within the utility sector. The nature of our supply chain is as follows: We work with a number of key direct suppliers who provide us with goods, such as equipment for our premises, and services, such as outsourced business processes, IT software, and marketing services.

For more information about the Company, please visit our website: https://www.mainlayer.com

Our Supply Chain

Our key supply chains involve procuring a wide variety of goods and services. Our suppliers are often well established and have a history of responsible trade with Main Layer Ltd. The evaluation and selection of suppliers for Main Layer’s supply chain is based on the supplier’s ability to provide goods that meet the required technical specifications as well as the need for satisfactory quality and service performance. These requirements are necessary to satisfy the movement of goods through the supply chain to fulfil the Main Layer’s own customer expectations.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

  • Recruitment and Selection Policy;
  • Supplier Code of Conduct;
  • Staff Code of Conduct;
  • Procurement Policy;
  • Safeguarding Policy;
  • Public Interest Disclosure Policy.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

  • Internal supplier audits;
  • Company values and policies.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains;
  • Monitor potential risks in our business and supply chains;
  • Reduce the risk of slavery and human traffic occurring in our business and supply chains.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

  • Evaluating the slavery and human trafficking risks of each new supplier;
  • Creating an annual risk profile for key suppliers;
  • Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We consider that we operate in a high-risk environment because our business operates in this risk level environment and every procedure is subject to our risk assessment requirements.

We do not tolerate slavery or human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Effectiveness

The company uses the following Key Performance Indicators (KPIs) to measure how effective we have been ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains.

These are as follows:

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

Any such claim coming to the attention of the company’s personnel would be reported to senior management through the company’s Public Interest Disclosure (whistleblowing) Policy. The board of director(s) will be informed of the issue, including the findings and outcome of the investigation.

 

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