Modern slavery statement
S54 of the Modern Slavery Act requires any commercial organisation in any sector which:
- supplies goods or services
- carries on a business or part of a business in the UK
- has a total turnover over of at least £36m
To produce a slavery and human trafficking statement for each financial year.
If any organisation in a group structure meets these requirements then they are legally required to produce a statement.
Small organisations are not legally required to produce a modern slavery statement; however, current government guidance encourages these to produce a statement. The government explains this is because smaller organisations will fall within the supply chain of a larger organisation who may wish to view this statement as part of their modern slavery strategy.
Although Humony’s turnover and number of employees is under the current UK legal requirement to publish a modern slavery statement, we felt it sat within our Company ethos to have one.
Organisation
This statement applies to Humony (referred to in this statement as ‘the Company’). The information included in the statement refers to the financial year 2019-20.
Company structure
We employ a relatively flat structure with 10 employees working from our office near Basingstoke, Hampshire. The organisation is privately owned.
The main activity is IT systems support. Demand is consistent throughout the year – generally carrying out the work on a daily basis for clients - and is not seasonal. The labour supplied to the Company in pursuance of its operation is carried out in the UK only.
Definitions
The Company considers that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
Commitment
The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
The Company does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and would consider that in many cases exceeds those minimums in relation to its employees.
Supply chains
In order to fulfil its activities, the main supply chains of the Company include those related to slings which are manufactured in the UK. Our suppliers assure us that their supply chains meet the UK standards with regard to modern slavery.
Potential exposure
In general, the Company considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Steps
The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
Review
If Humony engages with any new suppliers we will endeavour to ensure that such suppliers are not involved in modern slavery and/or human trafficking.
Anti-Bribery Policy
Definition
Bribery is, in the conduct of the Company’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.
Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by Humony’s employees or by third parties acting for or on behalf of Humony.
Purpose
The purpose of this policy is to convey to all employees and interested parties of Humony the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that Humony conducts its business in a fair, professional and legal manner.
Offences
It is a criminal offence to:
- offer a bribe
- accept a bribe
- bribe a foreign official
- as a commercial organisation, to fail to prevent a bribe
You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.
Definitions of bribery and corruption
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business:
Giving or receiving money, gifts, meals, entertainment or anything else of value.
As an inducement to a person to do something which is dishonest or illegal.
Scope
This policy applies to all employees of Humony, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.
We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers; contractors.
Policy
It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.
If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact Debbie Cooke or Ian Mckie so that action can be taken if considered necessary. You may be asked to give a written account of events.
If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to contact Debbie Cooke or Ian Mckie. You may be asked to give a written account of events.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.
The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.
Humony takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.
Staff are reminded of the Company’s Whistleblowing Policy which is available in the Employee Handbook, or upon request.
Gifts and hospitality
We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.
Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.
Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.
No gift should be given, nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from Debbie Cooke or Ian Mckie. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from Debbie Cooke or Ian Mckie.
A record will be made of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
Anti-Money Laundering Policy
Definition
Money laundering refers to a financial transaction scheme that aims to conceal the identity, source, and destination of illicitly-obtained money.
The launderer passes the money through a complex scheme of transactions to obscure who initially received the money from the criminal enterprise.
Money laundering is a criminal offence. The Company prohibits the act of money laundering. Humony require compliance, from everyone connected with our business, with the highest ethical standards and anti-money laundering laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by Humony’s employees or by third parties acting for or on behalf of Humony.
Purpose
The purpose of this policy is to convey to all employees and interested parties of Humony the rules of the Company in relation to our unequivocal stance towards the eradication of money laundering and our commitment to ensuring that Humony conducts its business in a fair, professional and legal manner.
Scope
This policy applies to all employees of Humony, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.
We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers; contractors.
Policy
It is prohibited, directly or indirectly, to accept money from illegal sources and/or to pay money out to illegal entities. Monies transferred through the Company must only be from known legitimate organisations, being customers, suppliers, staff and government bodies. Should money be obtained or paid out to any other entity the staff member must ensure Debbie Cooke or Ian Mckie are made aware.
The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.
Humony takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
Humony will uphold laws relating to anti-money laundering and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of money laundering or attempted money laundering has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.
Disclosure
Should a member of staff be concerned about the legitimacy of funds either coming into the Company or out of the Company you should immediately contact Debbie Cooke or Ian Mckie so that action can be taken if considered necessary. You may be asked to give a written account of events.
Summary
It is expected that instances of suspected money laundering will be rare given the nature of the services provided by Humony. However, we must be aware of the legislative requirements since failure to comply would have serious implications for both the Company and individuals concerned.
Staff are reminded of the Company’s Whistleblowing Policy which is available in the Employee Handbook, or upon request.