Modern Day Slavery

Purpose

We acknowledge responsibility to the Modern Slavery Act 2015 and the Human Trafficking and Exploitation (Scotland) Act 2015, and we accept that we have a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety, and human rights laws and standards are being adhered to, including freedom of movement and communication, freedom of workers to terminate employment, freedom of association, prohibiting any threat of violence, harassment and intimidation, prohibiting compulsory overtime and discrimination.

Scope

This policy includes all employees, contractors and suppliers for Pointer Ltd, PointerFire and JGE Security Systems.

Risks

We will assess each supplier on the importance of the products we purchase to the services we offer and their compliance to these policies. We will group suppliers based on strategic customers to analyse supply chain by customer. Any suppliers found to be non-compliant will be required to complete this process to allow us to assure our customers of compliance. This will be reviewed annually and approved by our Managing Director.

Risk Assessment Methodology

We will use the GSI Slavery Index to assess the risk of Modern-Day Slavery of a supplier (location based). The GSI Slavery Index of the country will be rated as follows:

We will categorise the supplier based on the products / services purchased, are we able to source elsewhere, our annual spend with the supplier and their performance. This will be reviewed annually.

We will multiply the Pointer Rating for GSI Slavery Index Value by the Supplier Rating based on the type of supplier / type of products or services they provide to us. If the supplier has control measures in place to control their Modern Day Slavery and monitor their own supply chain then we will reduce the score value by 1. (Slavery Index Rating x Pointer Supplier Rating) – Modern Day Slavery Controls)

The result will give a Residual Risk Rating which is then classed as either High, Medium or Low Risk using the key below:

Policy

This document details our controls, review and risk of Modern-Day Slavery through our organisation and our supply chain. We have an Anti-Slavery and Human Trafficking Policy Statement which is a summary of this policy.

Strategy

High risk areas for Modern Slavery will be identified in our Modern Slavery Risk Assessment, this will be taken from information supplied from our main suppliers.

Our Policies and Procedures

We have a Modern-Day Slavery Policy Statement in place which is available to all interested parties. This is to be reviewed and signed within 6 months of the financial year end (June 30th). We also have an Anti-Bribery Policy available to all interested parties on our website and also on our company app (Pointer Portal).

We have a Whistle-blowing Policy in place which allows for suspicions to be raised concerning modern slavery practices without fear of retribution. We have a Grievance Procedure accessible to all colleagues on the Pointer Portal and is easy to understand.

We have a Corrective Action and Improvement Procedure (PIP 26) available which sets out how we will investigate if issues are raised. Either a Root Cause Analysis Investigation is completed, or a Corrective Action Investigation through our Issues Register is completed by the manager responsible for the business area / supplier.

Our HR Department / Recruitment team work to Security Screening Procedure (PIP 29) for the recruitment and right to work checks for all new recruits. The HR Department have their own HR Procedures which are available to all colleagues and a Company Handbook which sets out the procedures for all colleagues.

We have a Control of Suppliers and Contractors Procedure (PIP 09), which sets out how we manage suppliers and contractors.

We have a Welfare Procedure (PIP 54) which sets out the requirements for welfare for our colleagues, this includes when we must provide welfare facilities as a Principal Contractor.

Responsibilities

We have appointed RA Rowan, Director as the senior individual to have responsibility for preventing modern day slavery.

The board reviews our Modern Slavery policy annually or when there has been a significant change / incident. This is included as part of our ESG policies.

Third Party Agreements

There are currently no Security and Fire trade agreements on human rights, ethical trade or corporate social responsibility. We are keen to ensure we participate with suppliers and customers who have a proactive approach to tackling modern slavery. We will review this on an annual basis.

We are committed to undertake certain steps through contractual agreements with many of our customers who are not exempt from publishing their modern slavery statement and seek to eliminate modern slavery in their supply chains. We will work with these partners as much as possible to meet these aims.

Staff Awareness

A toolbox talk is delivered to all our designers / managers / directors of the consequences of Modern Slavery / Bribery Acts and lays out our control measures in our Risk Assessment. This includes contacting suppliers who fail to meet these requirements. This is required to be completed regularly to ensure everyone is aware of the risk of Modern-Day Slavery.

All new colleagues will be required to complete this toolbox talk as part of their induction process and colleagues who account manage and work with our supply chain will be required to complete the toolbox talk. The main items will be included in regular refreshers.

New Suppliers

All new suppliers are required to complete a supplier questionnaire which asks for compliance to the Modern Slavery Act.

Existing suppliers are checked through their policies on their website or asked to provide their policies to ensure compliance.

Any new contractors are requested to work to our Modern Slavery policy if they do not have their own. This is part of the process in Control of Suppliers / Contractors. We will review a contractor’s Modern Slavery Policy when they submit it to us.

Existing Suppliers / Supply Chain

We have a list of our main suppliers, and we will engage with them regularly to review their Modern Slavery commitment and practices. This is done through an online questionnaire they are requested to complete. They will be required to upload a copy of their Modern Slavery Policy Statement. We will also check the gov.uk modern day slavery policy register.

Suppliers who complete the online form will be risk assessed based on their Modern Slavery Risks. Any high-risk suppliers will be required to provide more evidence for assurances.

We also ask suppliers if they are registered with third party checks to demonstrate their

Modern Slavery Commitments

Any small new suppliers are required to agree to our Modern Slavery Policy if they do not have their own.

Preventing Modern Slavery in our Business

We do not work with trade union bodies to ensure the proper treatment of workers. We do have Champions set up throughout our company who anyone can approach if they have concerns and need someone to raise the concern upwards. We also have our whistleblowing policy in place.

We have our own HR department who have their own procedures. Our procedures have been developed with the support of our company lawyers. We are compliant with UK law. All our colleagues are security screened to BS 7858:2019 as they are required to work in the UK Security Industry and as a requirement of our National Security Inspectorate (NSI) Gold membership.

Welfare is inspected by our managers throughout our offices in the UK. We also carry out audits of welfare facilities when our colleagues are working on sites. The audits are carried out by supervisors / managers / directors and our Compliance Manager.

Right to Work checks are carried out at the recruitment stage as part of the Security Screening Procedure (PIP 29) for all new recruits. This is completed as part of the requirements of BS 7858:2019.

Our finance team will check that Bank Accounts for salary payments are made to the named person and not anyone else. Proof of address is required as part of the Screening Process, this requires 2 forms of ID.

We have a QR code and signs available when any colleague, contractor, interested parties can report issues, including modern slavery issues. This can be submitted anonymously or through another colleague/champion.

All Modern Slavery concerns will be recorded in our Issues register and investigated by our Root Cause Analysis Report or a Corrective Action Report. These will be reported to Senior Management and discussed at the Management Review meeting.

Internal Audits are completed by the Technical & Compliance Manager to ensure compliance on an annual basis. The findings of these audits are reported at the Management Review meeting.

Audits are also completed on site where we are Principal Contractor, this would include questioning contractors present during the audit.

Management Review

The outputs from the risk assessment will be discussed at our Annual Management Review Meetings as part of our Management Systems and seek to create objectives, targets and programmes throughout the organisation.

Interested Parties

The policy and the policy statement will be reviewed as required to ensure its continuing suitability and relevance to our activities and is made available to all interested parties upon request. A copy is also available on the Modern Slavery Statement Registry Service hosted by gov.uk.

Engagement

We engage with our trade association, British Security Industry Association (BSIA). We also engage with our customers and certification schemes such as ECO Vadis, Supplier Approval Schemes.

Enforcement

The Managing Director and his management team will all receive minutes of the management review meeting. This includes all the issues raised and feedback provided from interested parties. The report shall be discussed with key members of staff and any improvements implemented.

An Internal Audit is completed to ensure that the agenda for management review is current and that management reviews are being completed and minuted as required.

The standard non-conformance form PIP 23 (Issues Register) should be completed for any deviations or difficulties encountered whilst operating this procedure.