MODERN SLAVERY STATEMENT
This statement sets out NW Security Group Limited actions to understand all potential modern slavery risks relating to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. NW Security Group recognises that it has a legal obligation to report on this issue. NW Security Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Sex or child sex trafficking, forced labour, bonded labour or debt bondage and domestic servitude.
In preparing this statement due consideration has been given to:
- The obligations placed on us as a result of the Modern Slavery Act 2015 - The Company recognises its moral and legal responsibility with regards to modern slavery and human trafficking, and as a minimum we will comply with all relevant legislation;
- Understanding the risks the business is exposed to as a result of going about its business. These risks arise as a result of the type of components purchased and consumed in the end products and their material content.
NW Security Group corporate values of Integrity, Learning, Disciplined Approach, Excellence and Innovation guide employees when making decisions about all aspects of the running of the business. In the case of labour exploitation or modern slavery, it is expected that all personnel responsible for the sourcing and specification of materials for use in the construction process act with Integrity to ensure that no action taken by the business is likely to adversely impact the human rights of people working in our supply chain wherever they may be and however far down the supply chain they may be.
NW Security Group has taken steps to review and update policies and management documents which are used in the course of selecting suppliers and managing their activities. As a minimum, it is expected that all suppliers and sub-contractors working on behalf of NW Security Group are fully compliant with local employment law and supply chain management laws.
The UK Government Modern Slavery Act 2015 requires NW Security Group to disclose annually online, as a minimum, the following:
- the organisation’s structure, its business and its supply chains;
- its policies in relation to slavery and human trafficking;
- its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
- the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
- its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate;
- the training about slavery and human trafficking available to its anti-bribery and anti-slavery legislation.
IDENTIFICATION OF FOREIGN WORKERS AND THEIR NATIONALITIES
NW Security Group follows all UK Government border control and HMRC guidance, which we constantly review to ensure that we are fully compliant. All documents used to verify the right to work are compliant with the Home Office Guidance Comprehensive Guidance for Employers on Preventing Illegal Working. The following controls are applicable to all potential or current employees.
- NW Security Group assures itself that all agency, self-employed, subcontracted personnel are eligible to work in the UK.
- National Insurance numbers will be requested and verified accordingly.
- Passports are requested and verified accordingly, and a copy taken for their personal file.
- Driving licenses are requested and verified accordingly, and a copy taken for their personal file. This is reviewed annually at their yearly appraisals.
- Once employed, each person is issued with an employment form which contains addresses, contact details, and next of kin.
Copies of all documents verified are retained for at least 5 years after the individual has left the employer. We will continue to monitor for changes in legislation and good practice in respect of human trafficking, exploitation, and slavery, including illegal working. As part of the policy review meetings, we will ensure policies are relevant and up to date in line with wider industry best practice and current legislation. We will continue to communicate the company’s obligations in these respects to other stakeholders, specifiers, and sub-contractors across the business.
Frank Crouwel, Managing Director
NW Security Group Limited
(Note: the above is an unsigned copy of our Modern Slavery Statement and Illegal Working Policy)