Modern Slavery Policy
Modern Slavery, Human Trafficking and Ethical Policy
1.1. Global Security and Disaster Management Limited (GSDM) is an independent training and consultancy company offering resilience solutions in response to conventional and emerging threats, risks and vulnerabilities.
1.2. GSDM is committed to the highest standards and practices of responsible business behaviour. Through our working practices we seek to protect and promote the human rights and basic freedoms of all of our staff and those partnering with us or supporting our activities in any way (e.g., our clients and suppliers), whether based in the UK or overseas. This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.
1.3. We are also committed to being a highly ethical Company in all of our internal and external conduct. The highest standard of integrity, honesty and accountability is of the utmost importance to who we are and what we do.
1.4. For ease, the term ‘staff’ is used here to mean employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.
MODERN SLAVERY AND HUMAN TRAFFICKING
2. OUR STANCE
2.1. Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every organisation is at risk of being involved in this crime through its own operations and its supply chain.
2.2. GSDM has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking in our operations and supply chain. We are committed to preventing and tackling all such activities as modern slavery and human trafficking as outlined here.
3. HUMAN RIGHTS
3.1. GSDM is vehemently opposed to all human rights violations, including the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.
3.2. We ensure that all staff are entitled to their human rights as set out in the Universal Declaration of Human Rights 1948 and international human rights law treaties.
3.3. GSDM will not enter into any business arrangement with any person who, or organisation which, fails to uphold the human rights of its staff or who/which breaches the human rights of those affected by the organisation’s activities.
4. OUR BUSINESS, SUPPLIERS AND PARTNERS
4.1. We establish a relationship of trust and integrity with all our clients, customers, suppliers and partners, which is built upon mutually beneficial factors.
4.2. Our supplier and partner selection and on-boarding procedure includes due diligence of their reputation, respect for the law, compliance with health, safety and environmental standards, references, as well as any other information considered relevant to ethical conduct issues (as appropriate).
4.3. We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers or partners, but if we were, then we would act immediately against the supplier or partner and report it to the relevant authorities.
4.4. More generally, GSDM expects all suppliers and partners to work towards and uphold similar ethical and moral standards.
4.5. GSDM reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who/which is found to have acted in contravention of the spirit or principles of this Policy.
5. RISK ASSESSMENT
5.1. In undertaking any risk assessment of our suppliers or partners, we take the following factors into account:
5.1.1. The risk profile of individual countries based on the Global Slavery Index;
5.1.2. The business services rendered by the suppliers and partners;
5.1.3. The presence of vulnerable demographic groups; and
5.1.4. A news analysis and the insights of labour and human rights groups.
This assessment will determine our response and the risk controls that we implement.
6.1. Additionally, GSDM takes a number of other measures to identify and prevent slavery and human trafficking in our operations as outlined here:
6.1.1. Whistleblowing Policy. We encourage all staff to report any suspicion of slavery or human trafficking in relation to our business activities without fear of retaliation.
6.1.2. Our Conduct. We encourage staff to do the right thing by clearly stating the actions and behaviour expected of them when representing the Company. We strive to maintain the highest standards of staff conduct and ethical behaviour including when operating abroad.
6.1.3. As and when appropriate, we conduct due diligence on all new suppliers and partners during on-boarding and thereafter at regular intervals. This includes ensuring that no form of forced, compulsory or slave labour is used by them.
6.1.4. Awareness. We have raised awareness of modern slavery issues by incorporating this statement and related policies within our Company (Staff) Handbook which is routinely updated and shared with all staff. These are aimed at:
- Highlighting our commitment in the fight against modern slavery;
- Identifying red flags for potential cases of slavery or human trafficking; and
- Explaining how staff should report suspicions of modern slavery.
6.1.5. Training. Where necessary, GSDM also undertakes training for its staff and any other party it is engaging with to cover such issues as:
- Various forms of modern slavery in which people can be held and exploited;
- The size of the problem and the risk to our Company;
- How staff can identify the signs of slavery and human trafficking, including unrealistically low prices;
- How staff should respond if they suspect slavery or human trafficking; and
- What external help is available for the victims of slavery.
It is a contractual requirement for all staff to fully respect and abide by all of GSDM’s policies, which includes this one on anti-slavery measures.
7. WORKERS’ RIGHTS
7.1 We are committed to complying with all relevant national and international employment legislation and regulations relevant to our business. The Company regards such regulations and legislation as the minimum rather than the recommended standard.
7.2. No worker should be discriminated against on the basis of age, gender, race, religion, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.
7.3. No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation.
7.4. Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum.
7.5. GSDM does not accept any corporal punishment, harassment in any form, or bullying in any form.
8. ENVIRONMENTAL ISSUES
8.1. We are committed to keeping the environmental impact of our activities to a minimum.
8.2. As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction we may be operating.
9. CONFLICTS OF INTEREST
9.1. GSDM holds as fundamental to its success the trust and confidence of those with whom it deals, including its staff, clients, customers, suppliers, partners and the beneficiaries of its services.
9.2. Conflicts of interest potentially undermine the relationship of an organisation with its partners. In order to help preserve and strengthen these relationships the Company has developed rules and guidelines regarding the giving and receiving of Hospitality and Gifts as part of its Anti-Corruption and Bribery Policy. These rules and guidelines govern the conduct of GSDM’s staff and are aimed at minimising the possibility of conflicts of interest.
9.3. All GSDM staff, as well as any others representing the interests of the Company from time to time, are expected to act honestly and within the law at all times.
10. INFORMATION AND CONFIDENTIALITY
10.1. Information received by GSDM staff or anyone else acting on behalf the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given. GSDM will at all times ensure that it complies with all applicable requirements of data protection legislation in force from time to time.
Should you use our products and services, we offer a free post-incident audit to review and assess their effectiveness in practice.