Anti-Slavery, Human Trafficking & Fair Work

Policy statement

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. Hamilton Brothers has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

Hamilton Brothers also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Hamilton Brothers accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for Hamilton Brothers or on the behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

This policy applies to all individuals working for the Company

Responsibility for the policy

The board of directors has overall responsibility for ensuring that this policy complies with the legal and ethical obligations.

Managers have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery.

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery in any part of the business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the control. You are required to avoid any activity that might lead to a breach of this policy.

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with the Disclosures in the Public Interest Policy. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

Hamilton Brothers aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Hamilton Brothers is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training and communication

Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

Hamilton Brothers has a zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of the policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

Hamilton Brothers may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

FAIR WORK FIRST & LIVING WAGE STATEMENT

The Hamilton Ross Group has a policy of staff empowerment. Under this policy we aim to develop each individual’s skills and ability to meet with the company policies and objectives. To achieve the above, we organise one on one discussions with employees via appraisals whereby dialogue is open to discuss training requirements and remuneration packages.

At present, the company employs 150 staff and has been working towards the living wage over the last two years. Currently, there are only employees below the living wage and the company is committed to achieving accreditation standard over the next 18 months. As part of our commitment to achieve living wage accreditation, management are tasked with nurturing and educating employees, via these appraisals, to work to company standards and achieve their full potential.
The company strives to be an equal opportunities employer and our Ethical, Gender, Equality and Diversity Polices have been made available to all staff and all are open to scrutiny as part of the Hamilton Ross Groups commitment to equality of race, gender, disability, and age.

Through our commitment to nurturing staff and creating a positive, non-discriminatory workplace environment we have maintained a high level of staff retention. All staff attendance and years of service are monitored annually along with staff turnaround percentage. At present the staff turn around over the last two years is tracking at under 25% which is low compared to most industries.

As part of our policy of staff empowerment the company believes in home grown talent, educating and developing skills from the age of sixteen through modern apprenticeships. The company, at present, has over 10 apprentices undertaking our programmes with more being added every year.

In addition, the Hamilton Ross Group is totally committed to non-zero-hour contracts, and we view them as a very negative and demotivational tool that will not be tolerated within the business. To meet with changes in living practices and family life, we also offer employees flexi time. Career breaks are considered on request, and we have seen young employees take six months to a year’s sabbatical to travel to New Zealand and Antarctica, returning to full employment thereafter.

In recent years, the Hamilton Ross Group has been making strides towards living wage accreditation and we have already seen the rewarding results with the improvement of skills.