The Modern Slavery Act of 2015

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The Modern Slavery Act came into force on 26 March 2015. The Act clarifies the existing offences of slavery and human trafficking and introduces tougher penalties. The Act includes a new requirement for commercial organisations such as CFBL to publish a statement each financial year setting out the steps we have taken to ensure that no slavery or trafficking is taking place in our business and supply chain.

 

The term ‘modern slavery’ describes exploitation so severe that people are not able to leave their place of work. ‘Slavery’ refers to the condition of treating another person as if they were property, something to be bought, sold, traded, or even destroyed. Victims may be ‘owned’ by their employers and controlled through means including massive recruitment debts that they are unable to pay off, and threats of harm if they try to leave. The significant characteristic of all forms of slavery is that they involve one person depriving another person of their freedom.

Situations that may present a particular risk of modern slavery include:

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• Where workers have fewer protections through inadequate laws and regulations, weak or non-existent enforcement, and poor business and government accountability.

• Where there are high levels of poverty among workers.

• Where there is widespread discrimination against certain types of workers (e.g. women and ethnic groups);

• Where there is the widespread use of migrant workers.

• In conflict zones, and.

• In some specific high-risk industries (typically industries involving raw materials).

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The risk of modern slavery affects almost every industry globally. As well as the potential for legal sanction, companies that fail to take effective action may also suffer severe reputational damage and loss of market share. CFBL takes this risk very seriously.

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Measures to address modern slavery in CFBL’s supply chains

- CFBL has undertaken the following measures to manage the associated risks of modern slavery in its supply chain:

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CFBL Policy

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CFBL has adopted the following policy on modern slavery:

“CFBL is committed to upholding the highest ethical and professional standards, and to maintaining public confidence in management accounting. As part of that commitment, we will use our best endeavours to identify and mitigate the risks of modern slavery and human trafficking by:

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• Never supporting or dealing with any business knowingly involved in slavery or human trafficking.

• Ensuring our suppliers and business partners understand our expectations of what acceptable business behaviour is, including this policy;

• Where necessary asking our suppliers and business partners to adopt suitable anti-slavery and human trafficking policies and procedures; and

• Encouraging the reporting of concerns and provide appropriate protection for whistleblowers.

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CFBL’s leadership team will ensure that staff are aware of this policy statement and that any further steps are implemented to prevent slavery and human trafficking within CFBL and its supply chains. This policy will be reviewed annually”. Staff are made aware of the Modern Slavery Policy and encouraged to report concerns to the Senior Leadership Team.

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Supplier policy

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All supplier policies dealing with modern slavery will be vetted during any procurement processes to ensure that they align with CFBL’s own policy.

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Contract Provisions

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CFBL will ensure that its contractual arrangements with new or existing suppliers support its modern slavery policy.  

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Whistleblowing

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CFBL will continue to encourage whistleblowing to identify breaches of policy and contractual provisions in respect of modern slavery. Reporting systems are in place to ensure that whistle-blowers identities are protected and that they have HR,

Procurement and Senior Leadership support.

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Supply Chain Assessment and Reviews

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CFBL will seek to identify vulnerabilities through supply chain assessment and reviews. While it is impractical for CFBL to audit and monitor each supplier in its entire supply chain at all levels, CFBL will identify key vulnerabilities and will take a risk management approach to ethical procurement and contracting. CFBL will ensure that its tender processes assist in assessing supplier compliance with the law.

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Action Planning

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For situations where corrective action is required, CFBL management will seek to address any issues with the appropriate level of management within the supplier. As a last resort, it may be necessary to terminate a relationship with a supplier.

 

Report on the 2020 Financial Year

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CFBL is not aware of any breach of the Modern Slavery Act 2015 in the context of its business operations or amongst its current supply chain during the financial year 2020-21.