Modern slavery is defined as a crime and a violation of basic human rights. Modern slavery can take various forms including (but not limited to) slavery, servitude, forced labour and human trafficking. This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
Modern Slavery Policy Statement
This is the modern slavery statement of Spring Operations Limited (Spring) and other UK subsidiaries within the group. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). This statement sets out the steps taken by Spring and other subsidiaries to prevent modern slavery in its business and supply chains.
Introduction
Spring has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all our business dealings and relationships. We have continued to implement and enforce effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere in our business or in our supply chains. We commit to follow up any concerns raised, take appropriate action and review this policy statement annually.
Suppliers
Spring provides home-buying and part exchange services to both direct-to-consumer and B2B partners. Throughout our supply chains, we are committed to high ethical standards, promoting safe and fair working conditions and responsible management of social issues. Our supply chains include contractors and consultants, primarily based in the UK, who provide various products and services.
For the minority of our suppliers that are outside of the UK, if modern slavery is identified or suspected, then the response will be tailored to the local circumstances, including engaging with local government, law enforcement, non-governmental organisations, industry bodies or trade unions.
Risk assessment and management
We have assessed our supply chains and whilst they are generally low risk, we share our policy with suppliers where the risk is higher. We have checked that suppliers have Modern Slavery policies in place where required and new suppliers are made aware of our zero-tolerance approach to Modern Slavery. Our whistleblowing policy encourages staff to raise any concerns about any wrongdoing and reports will be fully investigated. We will support anyone who raises genuine concerns in good faith.
Spring has robust recruitment processes, which include undertaking document checks on candidates prior to employment to evidence they have a right to work in the UK.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have appropriate staff training. During the induction process and throughout employment, training is provided to staff on topics relating to business ethics.
Reporting Concerns
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse, and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility to complete supplier due diligence and staff training in line with best practice.
Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If there is any uncertainty about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, it should be raised with HR. The government’s Modern Anti-Slavery and Human Trafficking Slavery Helpline can also be contacted on 0800 0121 700 for further information and guidance on modern slavery.
If a specific case of modern slavery is identified here in the UK, it should be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency number should be used. If staff identify a potential victim, they can be referred (with consent) to the National Referral Mechanism to be formally identified as a victim of modern slavery and offered Government-funded support.
Breach of Policy
Any breach of this policy by our employees could result in disciplinary action (including dismissal) and reporting to external bodies responsible for law enforcement. We will end our business relationship with individuals and/or organisations working on our behalf if they are found to be in breach of this policy and take no remedial action.
Further Information
UK Government Modern Slavery Webpage
www.gov.uk/government/collections/modern-slavery
Modern Slavery Act 2015
www.legislation.gov.uk/ukpga/2015/30/contents/enacted
The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 www.legislation.gov.uk/ukdsi/2015/9780111138847
Transparency in Supply Chains Consultation Document and Government Response www.gov.uk/government/consultations/modern-slavery-and-supply-chains
Anti-Slavery Commissioner
www.antislaverycommissioner.co.uk/
Alliance 8.7
www.alliance87.org/
The Head of HR is responsible for advising the Co-CEO of any modern slavery concerns raised and following up with relevant authorities (if relevant). The Head of Finance will ensure that our supply chain is aware of our zero-tolerance approach to modern slavery and will review the policy annually.
The Co-CEO has overall responsibility for ensuring this policy statement complies with our legal and moral obligations.