1.1 Wellcombe Group is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring its supply chains are free from slavery and human trafficking.
1.2 This statement sets out Wellcombe Group’s actions to understand 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.
1.3 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.
2.1 Modern slavery includes a range of types of exploitation, many of which occur together. These include but are not limited to:
3.1 The statement covers direct employees of Wellcombe Group, agency workers; and services delivered on behalf of Wellcombe Group by third party organisations and in the company’s supply chains.
3.2 Wellcombe Group engages in commercial activities by providing services delivered directly by employees and through external contractors; its annual turnover is less than £36million.
3.3 Structure
3.3.1 Wellcombe Group is made up of Wellcombe Group, William Alexander & Stellarmann. All operate solely from the United Kingdom.
3.4 Countries of operation & supply
3.4.1 Wellcombe Group is based in Brighton, in the county of Sussex, United Kingdom: Whilst the risk of slavery and human trafficking is considered low, Wellcombe Group remains vigilant and will take all steps available to manage the risks presented.
3.5 High-Risk Activities
3.5.1 Wellcombe Group will conduct dynamic risk assessments of their activities in assessing whether or not particular activities are high risk in relation to slavery or human trafficking. Any concerns should be raised initially with the officer responsible for Safeguarding.
The following activities are considered to be at high risk of slavery or human trafficking:
3.6 Responsibility
3.6.1 Responsibility for the organisation’s anti-slavery initiative is as follows:
4.1 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:
4.2 Whistleblowing policy: The organisation encourages all its employees 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 can raise the concerns through the mechanisms outlined in the Public Interest Disclosure (Whistleblowing) Policy.
4.3 Conduct and Standards policy: The organisation’s policy 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.
4.4 Employee Recruitment and Selection Policy: The organisation uses only reputable employment agencies to source labour.
5.1 Wellcombe Group’s due diligence approach to procurement includes a requirement to comply with this Modern Anti-Slavery and Human Trafficking Statement where turnover is less than £36million. Where turnover is more than £36 million due diligence includes ensuring suppliers have their own modern slavery procedures in place.
5.2 The organisation undertakes due diligence when entering into contracts with suppliers, and contract manages to ensure adherence to the Key Performance Indicators.
The organisation’s due diligence and reviews include:
6.1 Wellcombe Group uses the following performance indicators to measure how effective it has been to ensure that slavery and human trafficking is not taking place in any part of its business or supply chains:
7.1 Wellcombe Group has a programme of mandatory equality, diversity & Inclusion training for employees that enables them to identify and know how to report suspected or disclosed incidents of abuse, discrimination, bullying and neglect
7.2 Wellcombe Group has a programme of staff training specific to modern slavery and human trafficking.
This includes raising awareness of:
8.1 If you suspect modern slavery, please report to management as outlined in the Whistle Blowing policy or report it to the Modern Slavery Helpline on 08000 121 700. This helpline may also be used to seek advice.
8.2 All reports are fully investigated within 5 working days of the company becoming aware and appropriate remedial actions taken where required.
9.1 Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
9.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy/do not adhere to SLA.
10.1 Wellcombe Group will meet the following standards and expects those with whom it does business with, to meet these standards:
This statement was approved by the organisation’s Management Team who review and update it annually.
Approved: 23/01/2024
Ver: 13.0
Next Review Date: 22/01/2025
