Modern Slavery Statement
This statement sets out Lockesleys Electrical Services' actions to identify all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st April 2016 to 31st March 2017.
As part of the electrical industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational Structure and Supply Chains
This statement covers the activities of Lockesleys Electrical Services Ltd.
We are a London based S.M.E providing an electrical installation and repairs service across a broad base of differing clients. These include Social Landlords and private businesses.
The organisation currently operates in the following countries:
United Kingdom only
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Lockesleys undertake a stringent risk assessment process in relation to our operations in trading in various locations in reference to slavery and human trafficking, firstly by an initial written questionnaire to be completed by all of our key suppliers, ensuring that they, the supplier, have strong anti-slavery or human trafficking policies in place, and these polices are enforced, and also that they, the supplier (and their supply chains) are also fully compliant with the Modern Slavery Act of 2015.
The following activities are considered to be at high risk of slavery or human trafficking:
The key areas of our organisation's activities at a higher risk are the manufacture and production processes for our product lines, much of this is not UK based, with the implication that the labour force used in these manufacturing processes is not fully visible to us and so any workforce involved in this manufacturing process could potentially be exploited, or be high risk in relation to slavery or human trafficking, thus failing to meet one or more areas of policy and so not being compliant with the Modern Slavery Act of 2015.
Responsibility for the organisation's anti-slavery initiatives is as follows;
Policies: Our Owner is responsible for putting in place and reviewing policies and the process by which they were developed.
Risk assessments: The HR manager has broad organisational responsibility for human rights and modern slavery risk analysis, looking at processes/ ongoing reviews/ regular actions in this area to ensure we are compliant, meeting the requirements of the act.
Investigations/due diligence: Our HR manager is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
Training: Our HR manager is responsible for ensuring that all better understand and respond to the identified slavery and human trafficking risks.
The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
Whistleblowing policy. The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
Employee code of conduct. The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Suppliers code of conduct. The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
Recruitment/Agency workers policy. The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
The organisation requires all staff within the organisation to complete training on modern slavery
The organisation's modern slavery training covers
our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
how to identify the signs of slavery and human trafficking;
what initial steps should be taken if slavery or human trafficking is suspected;
how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
This statement has been approved by the organisation's Director, who will review and update it annually.
Director name: Colin Gallagher
Date: 1 st April 2019