Modern Slavery

1. Introduction

1.1 Stellarmann & William Alexander (Wellcombe Group) is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring its supply chains are free from slavery and human trafficking.

1.2 This statement sets out Wellcombe Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

1.3 The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2. The Modern Slavery Act 2015

2.1 Modern slavery includes a range of types of exploitation, many of which occur together. These include but are not limited to:

  • Sexual exploitation: This includes sexual abuse, forced prostitution and the abuse of children to produce child abuse images/videos.
  • Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties.
  • Forced labour: This can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars).
  • Criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker.
  • Other forms of exploitation include organ removal, forced begging fraud, marriage, and illegal adoption.

3. Organisational structure & supply chains

3.1 The statement covers direct employees of Wellcombe Group, agency workers; and services delivered on behalf of Wellcombe Group by third party organisations and in the company’s supply chains.

3.2 Wellcombe Group engages in commercial activities by providing services delivered directly by employees and through external contractors; its annual turnover is less than £36million.

3.3 Structure

3.3.1 Wellcombe Group is made up of Wellcombe Group, William Alexander & Stellarmann. All operate solely from the United Kingdom.

3.4 Countries of operation & supply

3.4.1 Wellcombe Group is based in Brighton, in the county of Sussex, United Kingdom: Whilst the risk of slavery and human trafficking is considered low, Wellcombe Group remains vigilant and will take all steps available to manage the risks presented.

3.5 High-Risk Activities

3.5.1 Wellcombe Group will conduct dynamic risk assessments of their activities in assessing whether or not particular activities are high risk in relation to slavery or human trafficking. Any concerns should be raised initially with the officer responsible for Safeguarding.

The following activities are considered to be at high risk of slavery or human trafficking:

  • There have been no reported or identified high risk activities at the present time

3.6 Responsibility

3.6.1 Responsibility for the organisation’s anti-slavery initiative is as follows:

  • Policies: Wellcombe Group’s Management Board is responsible for reviewing this policy and the Operations Manager is responsible for keeping under review contract procedures where a risk is identified in the supply chain. This policy will be reviewed on an annual basis or when legislation changes.
  • Risk assessments/investigations/due diligence: It is the responsibility of the Operations Manager alongside Management to ensure that procurement processes are robust in identifying risks in relation to slavery and human trafficking and explain their specific role.
  • Responsibility: It is the responsibility of the employee responsible for Safeguarding to ensure any risks or issues identified outside of the supply chain are dealt with appropriately and in a timely fashion and in accordance with safeguarding procedures.
  • Training: Wellcombe Group has a programme of safeguarding training for employees that enables them to identify and know how to report suspected or disclosed incidents of abuse and neglect, including modern slavery and human trafficking.

4. Relevant Policies

4.1 The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

4.2 Whistleblowing policy: The organisation encourages all its employees to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees can raise the concerns through the mechanisms outlined in the Public Interest Disclosure (Whistleblowing) Policy.

4.3 Conduct and Standards policy: The organisation's policy makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

4.4 Employee Recruitment and Selection Policy: The organisation uses only reputable employment agencies to source labour.

5. Due Diligence

5.1 Wellcombe Group’s due diligence approach to procurement includes a requirement to comply with this Modern Anti-Slavery and Human Trafficking Statement where turnover is less than £36million. Where turnover is more than £36 million due diligence includes ensuring suppliers have their own modern slavery procedures in place.

5.2 The organisation undertakes due diligence when entering into contracts with suppliers, and contract manages to ensure adherence to the Key Performance Indicators.

The organisation's due diligence and reviews include:

  • Mapping the supply chain broadly to assess products or geographical risks of modern slavery and human trafficking.
  • Ensure key suppliers confirm their adherence to Modern Day Slavery Act 2015 and human trafficking risks by reviewing on an ad hoc basis aspects of the supply chain
  • Contractors are required to hold relevant insurance cover required and will continue to for life of the contract.

6. Key Performance Indicators (KPIs)

6.1 Wellcombe Group uses the following performance indicators to measure how effective it has been to ensure that slavery and human trafficking is not taking place in any part of its business or supply chains:

  • All Employees & suppliers confirming their adherence to Modern Day Slavery Act (2015)
  • Employees made aware of Modern-Day Slavery Act 2015 and training provided as identified
  • All employees completed induction training
  • Number of cases reported (whistleblowing) and resulting action

7. Training

7.1 Wellcombe Group has a programme of mandatory equality, diversity & Inclusion training for employees that enables them to identify and know how to report suspected or disclosed incidents of abuse, discrimination, bullying and neglect

7.2 Wellcombe Group has a programme of staff training specific to modern slavery and human trafficking.

This includes raising awareness of:

  • the basic principles of the Modern Slavery Act 2015 and the company’s duties.
  • how employees can identify slavery and human trafficking and what to do if they have concerns.
  • what external help is available, for example through the modern slavery helpline.

8. Reporting Modern Day Slavery

8.1 If you suspect modern slavery, please report to management as outlined in the Whistle Blowing policy or report it to the Modern Slavery Helpline on 08000 121 700. This helpline may also be used to seek advice.

8.2 All reports are fully investigated within 5 working days of the company becoming aware and appropriate remedial actions taken where required.

9. Breaches of this Policy/statement

9.1 Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

9.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy/do not adhere to SLA.

10. Standards

10.1 Wellcombe Group will meet the following standards and expects those with whom it does business with, to meet these standards:

  • To support every individual’s human right to live free from abuse, servitude and inhumane treatment
  • To ensure a Diversity & Inclusion policy (or equivalent) is provided to all employees
  • To adhere to local and national laws including:
    • Prohibiting the use of worker-paid recruitment free
    • Prohibiting compulsory overtime
    • Prohibiting confiscation of workers original identification documents
  • To promote ethical business and operational practices in corporate activity and the services delivered, this includes:
    • Freedom of workers to terminate employment
    • Freedom of movement
    • Freedom of Association
  • To take appropriate steps to ensure that slavery and human trafficking is not taking part in any of its business or supply chains,
  • To take reports of witnessed, suspected or disclosed concerns of slavery and human trafficking seriously,
  • To take appropriate steps to address actual instances of slavery and human trafficking & provide access to remedy, compensation & justice for victims.

11. Board Approval

This statement was approved by the organisation’s Management Team who review and update it annually.

Approved: 23/01/2024

Ver: 13.0

Next Review Date: 22/01/2025

Ready. Set. Go.

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