THE MODERN SLAVERY ACT

Anti-Slavery and Human Trafficking Policy Statement

First Line is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively "human trafficking and slavery"). It also strongly believes that it has moral and ethical responsibilities for proactively promoting lawful employment practices.

First Line will not knowingly support or deal with any business involved in slavery or human trafficking. It will not knowingly accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour.

This policy statement is First Line's commitment to ensuring that human trafficking and slavery does not exist either within its own business, but also provides how First Line will take efforts to combat the same with other businesses where it maintains a relationship, especially from within its supply chain.

The Company Directors and Senior Management shall take responsibility for implementing this Policy statement and its objectives and shall provide adequate resources to ensure that slavery and human trafficking is not taking place in the organisation and within its supply chain. The level of management control required for these resources will be continually monitored.

The Policy takes into account and supports the policies and procedures within First Lines Business Management System ISO 9001 2015.

All Supplies are therefore required to adhere to the following:

Definitions
  • Human Trafficking: The recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

  • Forced Labour: All work or service not voluntarily performed and is obtained from an individual under the threat of force or penalty.

  • Harmful Child Labour: Consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child's education, or to be harmful to the child's health, or physical, mental, spiritual, moral, or social development.

  • Requirements for Suppliers:
    • Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;

    • Will ensure that the overall terms of employment are voluntary;

    • Will comply with the minimum age requirements prescribed by applicable laws.

    • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;

    • Will abide by applicable laws concerning the maximum hours of daily labour;

    • Will not engage in any practice of slavery , servitude , forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and

    • Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to First Line, also adhere to these requirements.

  • Certification: Suppliers will certify compliance with this Policy and there adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

  • Audits: Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of First Line. First Line may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

  • Reporting: Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting First Line's Company Secretary.

  • Consequences: First Line takes any breach of this Policy extremely seriously.
    Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with First Line terminated immediately, without compensation.

    If a Supplier to First Line is found in violation of this policy, First Line will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Board of Management shall determine to be necessary to address the violation and seek to prevent its reoccurrence.


This Policy will be reviewed annually. Previous versions of this statement are available on request. Contact info@firstline.co.uk

Signed: Dan Joyner - Managing Director
Date: 01/01/2019
Covers Financial Year Ending 31/12/2018, valid for 12 months.

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