Modern Slavery Policy

Modern Slavery Statement

Under the terms of the Modern Slavery Act 2015, Endersham does not meet the requirements for publishing a statement however we have a zero tolerance policy towards slavery and human trafficking and are committed to complying with the provisions in the Act. As such, we have taken the decision to publish this statement in order to make our position clear.


This statement applies to all companies within and associated to Endersham.


A) ORGANISATION


Endersham was founded in 1975


Endersham’s Head Office is in London at 5 Nugent Terrace, London NW8 9QB


The labour supplied to Endersham inpursuance of its operation is wholly carried out in the United Kingdom. Demand for Endersham’s services is consistently high throughout the year and is therefore not seasonal.


B) DEFINITIONS


Endersham considers that modern slavery encompasses:


• Human trafficking

• Forced work, through mental or physical threat

• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse

• Being dehumanised, treated as a commodity or being bought or sold as property

• Being physically constrained or to have restriction placed on freedom of movement


C) COMMITMENT


Endersham acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.


Endersham does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.


No labour provided to Endershamin the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Endershamstrictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and in many cases, we exceed those minimums in relation to our employees.


D) SUPPLY CHAINS


We have a zero tolerance policy to slavery and human trafficking and expect all those in our supply chain and contractors to comply with our values.


In order to fulfil our activities, Endersham’s main supply chains include those related to the supply of equipment, goods and services from various suppliers in both the United Kingdom and Europe. We understand that for some goods and equipment, Endersham’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.


E) POTENTIAL EXPOSURE


In general, Endershamconsiders its exposure to slavery/human trafficking to be relatively limited. Nonetheless, we have taken steps to ensure that such practices do not take place within our business, nor within the business of any organisation that supplies goods and/or services to us. Where possible we build long standing relationships with suppliers and make clear our expectations of business behaviour.


F) STEPS Endershamcarries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of our suppliers.


Endersham has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, Endershamhas taken the following steps to ensure that modern slavery is not taking place:


• We have transparent recruitment processes which are reviewed regularly, as well asrobust procedures in place for the vetting of new employees. We ensure we are able to confirm their identity and that they are paid directly into an appropriate personal bank account.

• To ensure a high level of understanding of the risks of modern slaveryand human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject

• We have in place systems to encourage the reporting of concerns and the protection of whistleblowers.


G) KEY PERFORMANCE INDICATORS


Endersham hasset the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place within Endershamitself, or in its supply chains:


• Use of labour monitoring and payroll systems

• Level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations


In the future we intend to:


• Put further measures in place to identify and assess the potential risks in our supply chains

• Review supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery


H) POLICIES


Endersham hasthe following policies which further define its stance on modern slavery:


• Corporate Social Responsibility Policy

• Ethical Policy

• Sustainable Procurement Policy

• Equal Opportunities Policy

• Quality Policy


I) SLAVERY COMPLIANCE OFFICER


Endersham hasa Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to BPR Group’s obligations in this regard.


This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Jamie Godsave
Managing Director
Dated: 07/01/2019

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