Modern Slavery Act

THE MODERN SLAVERY ACT 2015: A GUIDE TO WHAT IT IS and how it is integrated into Star Fasteners policies

Reviewed: January 2022

“It is simply not acceptable for any organisation to say, in the 21stCentury, that they did not know about slavery in the supply chain… By increasing supply chain accountability, more workers will be protected and consumers will have greater confidence in the foods and services they buy”.

Theresa May, UK Home Secretary

On 29 October 2015 the Modern Slavery Act 2015 came in to force and with-it new requirements for businesses to report on slavery and human trafficking. The purpose of this document is to give an insight of what it is and how we can stay on the right side of the law in following it. 

 

What is it?

The Modern Slavery Act 2015 is a UK act of Parliament designed to tackle slavery and human trafficking through the consolidation of previous legislation and the introduction of new measures. Specifically, it introduces new requirements for organisations in regards to their business and supply chains.

Does it apply to your organisation? Yes it applies to Star Fasteners

According to the Government’s issued guidance, any organisation in any part of a group structure will be required to comply with the provision and produce a statement if it:

  • is a body corporate or a partnership, wherever incorporated.
  • carries on a business, or part of a business, in the UK.
  • supplies goods or services.
  • has an annual turnover of £36,000,000 or more

As we do not have a total turnover of £36,000,000 – irrespective of the purpose for which profits are made, we do not need to publish a formal statement.

However, Star Fasteners need to be aware of this law and here are the basic points:-

The Modern Slavery Act will give law enforcement the tools to fight modern slavery, ensure perpetrators can receive suitably severe punishments for these appalling crimes and enhance support and protection for victims. It received Royal Assent on Thursday 26 March 2015.

The act will:

  • consolidate and simplify existing offences into a single act
  • ensure that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences)
  • enhance the court’s ability to put restrictions on individuals where it’s necessary to protect people from the harm caused by modern slavery offences
  • create an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery
  • introduce a defence for victims of slavery and trafficking
  • place a duty on the secretary of state to produce statutory guidance on victim identification and victim services
  • enable the secretary of state to make regulations relating to the identification of and support for victims
  • make provision for independent child trafficking advocates
  • introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
  • enable law enforcement to stop boats where slaves are suspected of being held or trafficked
  • require businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains

 

Star Fasteners Commitment

Our Policies & Practices in Relation to Modern Slavery

The Modern Slavery Act 2015 requires certain businesses to set out the steps they have taken to ensure slavery is not taking place in their operations and supply chain. We, as Star Fasteners (UK) are fully committed to playing our part in eradicating modern slavery.

 

What we already do

 

Our Employees

  • We ask that every employee takes seriously their role in building and protecting Star Fasteners reputation, by acting in full compliance with applicable laws and our values and ethical principles, in all of our activities.
  • During recruitment we are carry out various appropriate pre-screening checks across the business. This includes robust right to work checks pre employment.

 

Our Supply Chain

  • We assess risk in our supply chain (business, physical and volume related risks).
  • We review the areas of our supply chain where potential modern slavery risks may arise and develop targeted approaches to mitigating any risks.
  • We include specific clauses based on complying with the Modern Slavery Act 2015 within our standard agreement with suppliers.
  • These clauses outline our expectations of our supply chain and our approach to a range of issues including modern slavery and ethical conduct of our supply chain.
  • We base our supplier selection on objective and transparent criteria that include a consideration of environmental, social and ethical performance.
  • using a questionnaire for key suppliers; this includes questions on Modern Slavery and Human Trafficking.
  • We will assess instances of non-compliance of which we become aware, taking appropriate remedial action in a timely manner.
  • We are committed to ceasing trading with suppliers showing persistent disregard for important elements of environmental, social and ethical performance.
  • Our suppliers are required to notify us of any breach or potential breach of the Modern Slavery Act 2015.
  • Our agreements with our suppliers contain requirements for them to implement due diligence for their own suppliers and subcontractors to ensure there is no slavery or human trafficking in their supply chain.

 

Our Future Plans

To ensure our business and supply chain are slavery free by monitoring and reviewing our internal processes and developments in the law.