1. PHS Home Solutions Limited (PHS) Policy Statement
1.1. The Modern Slavery Act 2015 (the ‘Act’) requires organisations whose turnover exceeds £36m per annum to prepare and make available a statement on slavery and human trafficking each financial year. The Government encourages all businesses to develop an appropriate and effective response to modern slavery. Businesses may choose to take further action over and above what is prescribed by the Act but this will be a decision for individual businesses themselves. PHS turnover now exceeds the threshold requirement, and our Statement and Policy addresses the requirements as stated in the legislation. This also demonstrates that PHS is a responsible employer with strong CSR (Corporate Social Responsibility) initiatives. This ensures our Statement and Policy means we are compliant with The Modern Slavery Act 2015.
1.2 PHS considers that modern slavery and human trafficking in all their various forms and guises are a crime in the UK and much of the world and a violation of fundamental human rights.
1.3 PHS has a zero-tolerance approach to modern slavery and human trafficking and are committed to acting ethically and with integrity in all activities and business relationships and we expect and encourage our supply chain, contractors, employees and all other business partners to commit to the same, irrespective of the financial threshold, including implementing and enforcing effective systems and controls to prevent and detect modern slavery.
1.4 The Act applies to all organisations with a turnover, that is, the total turnover of a company and its subsidiaries – of £36 million or more which are either incorporated in the UK or carry on a business in the UK. Section 54 of the Act requires those organisations to prepare and publish a statement setting out the steps that they have taken during that financial year to ensure that slavery and human trafficking are not taking place:
• anywhere in their supply chains;
• in any part of their own business.
The law came into force on 29 October 2015. The requirement to publish an anti-slavery statement only applies for financial years ending on or after 31 March 2016. PHS commits to publishing an annual statement on modern slavery and human trafficking. The turnover for PHS and its wholly owned subsidiary Oakes Energy Services Limited is likely to exceed the £36m threshold in the Accounts which will be published on Companies House for financial year ending
31 March 2022. This means that PHS is “relevant” under the legislation and is therefore is required to provide a statement and post this onto its website.
2. Our Business
2.1 The economic, social and environmental footprint of our business activity is a fundamental consideration in PHS commitment to responsible and sustainable business growth. PHS has been trading since 2003 providing appliance repairs and heating installations with associated works throughout the United Kingdom.
3. Responsibility for the Policy
3.1. The Directors and senior management team of PHS have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all persons working for us or on our behalf in any capacity comply with it.
3.2. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all persons working for us or on our behalf in any capacity (including our employees, suppliers, workers, directors, agents, distributors and all third-party business partners to include subcontractors).
3.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issue of modern slavery in supply chains.
4.1. PHS understands the risks associated with modern slavery and is committed to ensuring that robust systems and controls are in place to prevent slavery, human trafficking, child labour and labour exploitation occurring in it’s business or in any part of it’s supply chain.
4.2 PHS has implemented and is enforcing a number of measures, policies and controls both internally and externally to ensure compliance with the requirements of the Modern Slavery Act 2015.
4.3. Training on this policy and the risk our business faces from modern slavery and human trafficking forms part of the induction process for all individuals joining the business and an internal training and learning module has been created for all existing staff employed in a purchasing function. Regular refresher training will be provided as required.
4.4. The issues surrounding modern slavery and human trafficking has been added to the PHS employee Handbook which is available to all employees.
4.5. PHS has created a Supplier’s Charter and, in our Terms, and Conditions of Purchase have been amended to encompass modern slavery and human trafficking, a copy of which is available to our suppliers upon request.
4.6. PHS will not knowingly transact with any partners who are in breach of acceptable legislation and regulations including health and safety, environmental and employment laws.
4.7 PHS is committed to a programme of continuous improvement and maintaining quality management systems which incorporate the following international standards for which it holds external accreditation: ISO:9001, 14001, 27001 and 45001. These management systems are externally audited at least annually to ensure full compliance to the standard and the external accreditations are maintained.
5.1 All persons working for PHS or on our behalf in any capacity must:
5.2 read, understand and comply with this policy, and avoid any activity that might lead to, or suggest, a breach of this policy;
5.3 Notify their immediate manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future; and
5.4 Raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
6. Breaches of Policy
6.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
7. Ongoing Review
7.1. PHS commits to ongoing review of its supply chains and external operations and internal operations to check compliance with the above policy, and to check that our policy is being implemented effectively.
8. Making the Statement Available
8.1 Copies of this annual statement will be made available upon request and will be printed and sent to anyone requesting this within 30 days of receipt of the request.
8.2 Company Responsibility. The Compliance Director is responsible for ensuring business corporate compliance with the legislation relating to the Modern Slavery and Human Trafficking, generating, planning and communicating the Policy and statement, delivering all actions associated with meeting the company’s obligations as part of this statement, communicating the Annual Statement and the company Policy and then ensuring this is posted onto our website. Together with the Senior Management team, this statement will be reviewed at least annually or in response to any major or organisational change, legislative change or following any breach or concerns about any aspect of modern slavery, human trafficking, child labour exploitation or any other labour exploitation. The
Further Information and Background: See link to the Government Publication as issued by Theresa May when Home Secretary.
2. The Modern Slavery Act 2015
3. Who is required to comply?
4. Writing a slavery and human trafficking statement
5. The Structure of a Statement
6. Commencing the provision
7. Approving a statement
8. Publishing a statement
9. Responding to an incidence of modern slavery
Annex A – Modern Slavery Definition
Annex B – Section 54 – Transparency in supply chains etc
Annex C – Example of a group structure with a subsidiary based abroad
Annex D – The Act in the context of other reporting requirements
Annex E – Information in a slavery and human trafficking statement
Annex F – UK Modern Slavery Adult Victim support providers
Annex G – Useful Information and Resources