Modern Slavery Act

Modern Slavery and Human Trafficking Statement (2023)

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015.

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. Full Circle Compliance Ltd are committed to preventing modern slavery and human trafficking in any part of its business or supply chains.

Structure and supply chains

Full Circle Compliance Ltd are a privately owned company working in the United Kingdom, specialising in Asbestos Compliance Services. We are proud of the ethical standards embedded in the business. We believe these standards are consistent with the underlying principles of the Modern Slavery Act 2015. We recognise that unfortunately Modern Slavery does occur within the construction industry and its supply chains and are committed to combat modern slavery and human trafficking.

We have a varied supply chain spanning a wide range of disciplines. We believe the risks mainly lie with the lower skilled trades and workforce. Operating closely with our supply chain, we identify potential areas of risk and work in collaboration with them to mitigate these risks.

Policies on modern slavery

Full Circle Compliance Ltd operates a zero-tolerance approach to modern slavery that highlights our commitment to ensuring that appropriate and co-ordinated action is taken throughout the business.

Due Diligence process

We undertake various due diligence checks with our supply chain to ensure modern slavery should not occur within their jurisdiction. This is demonstrated through the following:

  • Supply chain competency checks
  • Specific requirements within their contracts
  • Questionnaire within pre-contract meeting confirming compliance
  • Declarations of compliance with our policy
  • Right to work checks
  • Awareness training on site
  • Regular reviews and assessments
  • Risk assessment

Full Circle Compliance Ltd have reviewed and assessed the risks and understand that the biggest concern lies in our supply chain and particularly their supply chains. We are taking the necessary steps to ensure that our supply chains undertake their own checks in respect of ethical risks when subcontracting themselves.

To mitigate these risks we have put in place various measures within our due diligence process.

Measuring effectiveness

We have in place a number of performance measures to ensure compliance with our policy in respect of modern slavery. This includes measurement of training, site compliance and supply chain performance.

Training for staff

To ensure high levels of understanding of the risks associated with modern slavery and human trafficking, relevant employees within the Full Circle Compliance Ltd will be required to complete e-learning training. As well as training employees, Full Circle Compliance Ltd commits to raising awareness of modern slavery issues by circulating a series of details to all employees and using a poster campaign. The campaign will explain to employees:

  • the basic principles of the Modern Slavery Act 2015.
  • how employers can identify and prevent slavery and human trafficking.
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Our supply chain are also required to complete relevant awareness training.

Full Circle Compliance Ltd also supports Anti-Slavery Week, raising awareness amongst staff, customers and supply chain through a range of social media and internal communications channels.

Future Plans

Each year we reassess the effectiveness of the actions we have taken in the previous year to highlight modern slavery or human trafficking and use this assessment to develop our plans.

In 2024 Full Circle Compliance Ltd will:

  • Progress with delivering the actions identified in our Action Plan, measuring and reporting progress.
  • Create opportunities to work with our colleagues on supply chain mapping.
  • Include site visits on targeted ‘high risk’ supply chains.
  • Continue to identify modern slavery risks within our supply chains and act to remove these where possible, with the support of our suppliers and the Action Plan.
  • Review our Modern Slavery Policy and continue to develop our policies in line with good practice and procedures.
  • Raise the profile of Modern Slavery through training and awareness events, including promoting Anti-Slavery Week.
  • Further develop the commitment of contractors to map and risk assess their own supply chains as part of the contract performance indicators.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking Statement for the financial year ending 31st October 2024.

Kevin Craig

Managing Director

November 2023

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