Modern Slavery

Modern Slavery and Human Trafficking Statement

1.   Introduction

This statement sets out Clean Genesis Limited approach to any situation where it becomes aware of, or has evidence of involvement or risk of involvement whether directly or indirectly that subjects people to conditions that meet current definitions of modern slavery, human trafficking and forced labour.

As part of the cleaning sector, the organisation (Clean Genesis Limited) is committed to preventing modern slavery and human trafficking in all its business activities

While we currently fall below the £36 million annual turnover thresholds mandating that we publish a statement in line with Section 54 of the Modern Slavery Act 2015, and even though we will not currently be subject to the Act’s annual reporting requirements, Clean Genesis Limited understands the Importance of tackling modern slavery which has led us to a voluntary publication of this statement.

2.       Organisational Structure and Supply Chains

Clean Genesis Limited is a commercial and Domestic Cleaning service provider. The organisation currently operates in the United Kingdom.

Supply chains can be complex as it involves a wide range of suppliers, subcontractors and partners; therefore we are committed to working with suppliers who share the same values and commitment to a sustainable business practice.

We will communicate to our supply chain our expectations in relation to human rights, labour practices, environmental sustainability and business integrity and we will also ensure that key members of our supply chain can also demonstrate this commitment as well.

We make all efforts through our supplier monitoring to ensure that no link in the supply chain is producing goods and services made under conditions of modern slavery or which might involve human trafficking.

We Follow the below process to ensure our business activities is free from modern slavery or human trafficking.

Staff and Recruitment

·         All recruitment of employees follows UK legislation, good practice and procedures in compliance with employment law and registration requirements with pay and conditions of employment that meet all statutory requirements.

·         We do not employ staff under any condition that might make us vulnerable to accusations or suspicions of modern slavery and exploitation as defined.

·         Training and Induction of new workers include information on modern slavery and how to spot potential issues that might have breached modern anti-slavery law and how to respond to any suspicions or evidence of breaches in the law.

Responsibilities

·         Policies and procedures: Human Rights Policy and Ethical Rights are in place which is reviewed annually by the HR team.

·         Investigations and due diligence: Investigations in relation to human slavery or trafficking is carried out by the HR team.

·         Supply chain/procurement: Potential and existing Supplier audits elements of which relate to slavery or human trafficking are carried out by the Procurement and Technical teams.

Policies and Procedures

Clean Genesis Limited has a zero-tolerance approach to modern slavery and human trafficking. With policies and procedures in place to ensure that our business activities and supply chains are free from these practices.

The policy will include our commitment to ensure provisions are included to minimise risks associated with.

·         Adherence to local and national laws

·         Freedom of workers to terminate employment

·         Freedom of movement

·         Freedom of association

·         Prohibits any threat of violence, harassment and intimidation

·         Prohibits the use of worker-paid recruitment fees

·         Prohibits compulsory overtime

·         Prohibits child labour

·         Prohibits discrimination

·         Prohibits confiscation of workers original identification documents

·         Provides access to remedy, compensation and justice for victims of modern slavery

Whistle blowing policy: The organisation encourages all its workers, customers and business partners to report any concerns related to the activities or supply chains of the organisation, including circumstances that may give rise to the risk of slavery and human trafficking. Employees can make disclosures without fear of retaliation or discrimination. Customers can also confidentially implement this policy at anytime if they have concerns.

Employee Code of Conduct: This is embedded within our Employee Handbook and sets out our expectations of ethical behaviour from all our employees and our policy will be clearly communicated during the onboarding process.

Supplier Code of Conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of operations and demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect and in accordance with the law.

3.       Performance Indicators

We monitor our performance on modern slavery and human trafficking through regular risk assessments and audits of our business activities and supply chains.

We encourage our employees and suppliers to report any concerns or suspicions of modern slavery or human trafficking to us.

We will review and update our policies and procedures as necessary to ensure that we remain updated with laws and regulations relating to ethical and sustainable business practices

4.       Due Diligence

Clean Genesis Limited undertakes due diligence when considering taking on new suppliers and will regularly reviews its existing suppliers. The organisation's due diligence and reviews includes: 

• Mapping the supply chain broadly to assess particular products or geographical risks of modern slavery and human trafficking.

• Regularly review all aspects of the supply chain based on the supply chain mapping.

• Supplier audits are conducted through the organisation's own employees, where general risks applies.

• Participating in collaborative initiatives such as  the "Stronger together" initiative; focused on human rights in general, and human trafficking in particular.

• Using Ethical Trading Initiatives (ETI) database, where we can check the labour standards of suppliers,compliance in general and modern slavery.

• Sanctions will be invoked against suppliers that fail to improve their performances or violate our suppliers code of conduct, including termination of the business relationship.

5.       Conclusion

Clean Genesis Limited is committed to tackling and preventing modern slavery and human trafficking in all its business activities. This is an ongoing process, and we will continue to work with our employees, suppliers, and partners to ensure that we maintain the highest standards of ethical and sustainable business practices.