Modern Day Slavery Policy
Author: Head Of People
Issue Date: 06/04/2024
Our Workforce
Principle Cleaning Services is committed to do our part towards the prevention of modern slavery and human trafficking by respecting and protecting the human rights of all employees. The Company currently employs under 3,000 employees, this includes our employees on site, Management and Head Office personnel.
All employees are vetted according to our Recruitment and Vetting Policy, paid above minimum wage and paid directly into their own bank accounts. The HR/Payroll departments are responsible for checking all new employee documents to ensure they comply with the policy and the Home Office requirements.
Our Whistleblowing Policy ensures that employees are able to discuss any concerns they may have with a member of HR or Line Management. Staff are encouraged to communicate any suspicions they may have and if they think a colleague may be affected by slavery or human trafficking. The Company has a confidential email address to HR hr.confidential@principleclean.com where staff can air their concerns. All concerns raised are treated as confidential.
Definitions
Modern-day slavery– refers to all forms of slavery, servitude, forced labour and human trafficking which are illegal under the Modern Slavery Act of 2015
Human Trafficking- illegal trading of humans for the purpose of forced labour, sexual exploitation or other forms of exploitation
Money Laundering- concealing the origins of illegally obtained money, for example through transfers of foreign bank accounts or through businesses
Our Supply Chain
The Company works with a number of subcontractors and suppliers who enable us to deliver our service to our clients. All our subcontractors must complete a pre-qualification questionnaire and supply compliance documentation before being approved.
Our main subcontractors are closely managed by our Operations Team, compliance checks are made every three years, and quarterly KPIs are monitored.
Compliance audits of our subcontractors will also include checks on their own Modern Slavery Policies and company risk assessments. We have identified that our suppliers’ own supply chains may be a high risk where factory work, including out of the UK, may take place. It is therefore our responsibility to ensure that our suppliers are themselves monitoring their contractors.
Assessment of modern day slavery risk
Potential risks of Modern Day Slavery can include:
- Exploitation of vulnerable people and practices could include human trafficking and restrictions on movement
- Withholding wages/salaries such as taking some or all of the wages paid to an employee
- Money laundering
- Reputational damage
Commitments for 2025-2026
Principle Cleaning Services will ensure:
- transparency about our steps to prevent modern day slavery, as mentioned in this policy
- work with our suppliers and other stakeholders to address modern day slavery risks
- to not take part in money laundering and aim to educate all employees on the importance of avoiding money laundering by 2030
- this policy is communicated to our workforce and the necessary training is provided
- the vetting process is monitored and remains effective
- the HR department details are available to staff on all sites as is our Whistleblowing Policy
- Review risk assessment identifying potential high risk activities/areas
- Carry out random audits on our contractors in relation to vetting of staff and contractors
Principle Cleaning Service’ Board of Directors will remain committed to the prevention of Modern Day Slavery and Human Trafficking ensuring that an active approach is taken at all levels.
Signed by: Catherine Imoisili
Head Of People
Date: 06/04/2024
