This statement sets out the steps Portman Co. take for ensuring that no slavery or human trafficking exists in any part of our business or wider supply chain. Modern Slavery is a term used to encompass the offenses outlined in both the Modern Slavery Act: slavery, servitude and forced or compulsory labor; and human trafficking.

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As a business, we have a responsibility to ensure that workers are not exploited in any way, that they are safe from harm, and that relevant employment, health and safety, human rights laws, and international standards are met and adhered to, including freedom of movement and communications. We are committed to ensuring that our processes are in place, fit for purpose, and amended as and when required by law so we can raise awareness of the issue and responsibilities amongst our people and supply chain.

 

Our supply chain consists of sub-consultants, sub-contractors, and professional service providers, together with suppliers of services and equipment to our offices. We consider the risk of modern slavery and human trafficking within our recruitment, working practices, and supply chains as very low risk, and with the continual review of our supply chain, we can identify those which are high risk.

 

Policy.

We undertake pre-employment checks to ensure that all employees are eligible to work in the UK and stipulate that those in our supply chains also carry out the same level of due diligence concerning agency workers, temporary staff, contractors, and others.

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Where third parties provide products or services to us, we have an established and comprehensive due diligence process for their engagement, ensuring that their conduct and working practices are consistent with those of Portman Co. We employ a zero-tolerance policy to slavery and human trafficking and expect all of our employees and supply chains to comply with our policies, values, and relevant legislation. To protect our employees we have several internal policies and procedures, these include:

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• Equality Diversity Policy and Procedure.

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• Whistleblowing Policy and Procedure.

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• Recruitment Policy and procedure.

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In addition, our Supplier Code of Conduct explains for the benefit of all of our suppliers and our employees our expectations regarding ethical behavior. 

 

Due diligence.

Portman Co. regularly reviews its existing product and services providers to ensure they are complying with the provisions of the Modern Slavery Act 2015, and Portman Co. policies and procedures and takes steps to prevent modern slavery and human trafficking within their business and supply chains. The appointment of new products or service providers will be expected to adhere to the Modern Slavery Act and our Supplier Code of Conduct.

 

Training.

This statement and the Supplier Code of Conduct will be communicated both internally and externally via several methods including our website, intranet, letters of appointment, and marketing material to uphold a good understanding of the risks of modern slavery and human trafficking within our business and supply chains.

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We aim to increase awareness concerning modern slavery and human trafficking and expect our people and our supply chains to raise concerns at the very earliest possible moment.

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Key performance indicators (KPI's)

Portman Co. look to and monitor KPI performance concerning the promotion and adherence of its Modern Slavery and human trafficking policies and procedures. We will continue to review and improve our performance in the mitigation of modern slavery and human trafficking ensuring that it does not exist throughout our business.

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This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the members of Portman Co Ltd.

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