Consolidated Investment Holdings Ltd
Modern Slavery Statement for financial year 2018/19
This statement is made pursuant to s.54 of the Modern Slavery Act 2015. Whilst the Company does not directly employ any staff it is recognised that the Management Services Provider (MSA), Albany SPC Services Ltd, has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within the business or supply chain.
The Company values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of parties associated with the Company including Directors are key to maintaining standards.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Company has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
1. Recruitment policy for Albany SPC Services Ltd. The Company does not have any employees. However, Albany SPC Services Ltd which is the employer for MSA Services for the Company operates a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing policy for Albany SPC Services Ltd. The Company does not have any employees. However, Albany SPC Services Ltd which is the employer for MSA Services for the Company has requested subcontractors to confirm its whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. Policies for Albany SPC Services. Albany SPC Services Ltd which is the employer for MSA Services for the Company, operate policies which explain the manner in which we behave as an organisation and how we expect our suppliers to act as evidenced through their policies.
The Company works with the MSA provider who it is recognised, conduct due diligence on all key subcontractors and suppliers. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions. Suppliers have been asked to confirm to the MSA provider that no part of their business operations contradicts this policy.
Suppliers confirm to the MSA provider that:
1. They have taken steps to eradicate modern slavery within their business
2. They hold their own suppliers to account over modern slavery
3. For UK based suppliers that they pay their employees at least the national minimum wage / national living wage (as appropriate)
4. For international suppliers that pay their employees any prevailing minimum wage applicable within their country of operations
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from the MSA provider, the public, or law enforcement agencies to indicate that modern slavery practices have been identified and that our MSA provider and their key subcontractors are willing to comply with all applicable points in this statement
The Board will review this policy and the associated management system annually.
This Statement was approved by the Board of Directors on 31 October 2018.
This Statement was signed for and on behalf of Consolidated Investment Holdings Ltd by Ailison Mitchell, Company Secretary on 31 October 2018.