Anti-Slavery and Human Trafficking Policy
ERSG has relationships with various types of suppliers, the majority of whom are professional contractors working in the energy sector. Following the passing of the Modern Slavery Act 2015, ERSG has reviewed its existing compliance and risk management processes to determine to what extent measures already exist and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains. This policy underpins our approach and will be used to inform our Statement on Slavery and Human Trafficking which is due to be published next year.
ERSG has adopted a statement of its corporate values on the prevention of modern slavery and human trafficking. The value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or whom we appoint to act on our behalf.
We expect all who have, or seek to have, a business relationship with ERSG to comply themselves with this statement and to act at all times in a way which is consistent with our anti-slavery values.
ERSGs Anti-Slavery Commitment
As part of our culture of good ethics and practice ERSG operates a set of values which reflect our relationships with our principal stakeholders: customers, shareholders, suppliers, contractors and employees. In all of its business dealings, ERSG opposes the exploitation of individuals in any form, particularly the offences created by the Modern Slavery Act 2015. ERSG is committed to opposing modern slavery in all its forms and preventing it by whatever means possible. ERSG expects the same of all who work for and with it.
1.1 Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the "Act"). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of ERSG with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy's use of the term "modern slavery" has the meaning given in the Act.
1.2 ERSG has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensuring modern slavery is not taking place anywhere in its business or supply chain.
2. Steps for the prevention of modern slavery
2.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery through out our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors and suppliers, and we are updating our processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude. We expect our suppliers to hold their own suppliers to the same requirements.
2.2 All employees and suppliers are required to comply with ERSG’s procedures to prevent modern slavery and to conduct business in a manner such that modern slavery is prevented.
2.3 While ERSG complies with the Modern Slavery Act 2015, it acknowledges that it does not control the conduct of those in our supply chains. To underpin our compliance with practical steps, ERSG intend to implement the following measures:
(i) conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas:
(ii) engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses:
(iii) seek to introduce supplier pre-screening (for example as part of our tender process) and self-reporting for our suppliers on safeguarding controls:
(iv) introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
2.4 From financial year 2016, ERSG will include in the directors' report accompanying its annual financial statements a reference to its Slavery and Human Trafficking Statement which will be presented on our website during the course of 2017.
3. Responsibility for the policy
3.1 Responsibility for the prevention and prevention of modern slavery rests ERSG’s Directors and senior management. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.
3.2 Managers are responsible for ensuring that their staff understand and comply with this policy and are given training on it.
4. Actions to report modern slavery or human trafficking
Whistleblowing Procedure - direct access to senior management.
ERSG's Whistleblowing Procedure is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner. The Whistleblowing Procedure applies to all employees.
Employees should raise any concerns with a Director of ERSG or their Country Manager as appropriate.
Concerns should be raised if any employee or any supplier:-
suspects a person acting on behalf of ERSG is seeking to exploit another in a way which could amount to modern slavery;
suspects that a person acting on behalf of one of ERSG’s suppliers is seeking to exploit another in a way which could amount to modern slavery;
has received an approach from a person acting on behalf of ERSG who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;
has information which leads to the reasonable conclusion that a person acting on behalf of ERSG or any supplier is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.
Reports will be kept confidential other than where ERSG is required to pass information to relevant authorities.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.
However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.
Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against an employee making such claims or allegations.
6. Communication and awareness of this policy
Our zero-tolerance approach to modern slavery must be communicated to all suppliers and contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by ERSG’s Directors on a regular basis (at least annually) and may be amended from time to time. This Policy will be used to inform our Statement on Slavery and Human Trafficking which will be published no later than the publication of our 2016 financial results.