MODERN SLAVERY & HUMAN TRAFFICKING POLICY

CK Facilities Management Limited recognise that our industry and the use of largely unskilled labour is susceptible to exploitation of people by unscrupulous intent. We understand that getting paid does not necessarily signify that work isn’t forced and thatlabour should be given freely and that employees should have the right to leave.

Although well below the reporting turnover under the Modern Slavery Act 2015 we fully accept that we have a duty to aspire to the aims of the Ethical Trading Initiative.

We fully comply with all applicable laws and regulations in all of our operations and strive to conduct ourselves in a professional manner with high standards of honesty and integrity. We ensure that all staff follow Company policies and procedures in their dealings with others and with our suppliers.

The Company work with our supply chain and understand where the products which we use and supply come from and that, where there is a risk, we seek assurance from our suppliers of their commitment to ethical sourcing.

We have identified areas which may cause a problem (recruitment fees, migratory workforce areas, comment on abuses in areas from where we purchase) and deal only with manufacturers who similarly recognise these “red flags” and aim to avoid them. We ask for transparency in areas of sourcing by our suppliers’, examples can be the recruitment of labour, purchase of stationery, paper products, machinery, chemical supplies, janitorial and other products, many of whom subscribe to the Base Code of the Ethical Trading Initiative, and we regularly review our approved suppliers list. Where available we review their corporate responsibility policies and adopt government guidance.

As a Company we are happy to answer questions in tenders about our training, wage structure, internal policies and reporting processes and we never pay below the Living Wage, striving instead to encourage our clients to meet the aspirations of the Living Wage Foundation rates. Our operatives are not asked to work excessive hours, these being defined in their Statements of Terms and Conditions, or work in an unsafe environment and all tasks carried out by them are risk assessed and reviewed regularly. Overtime is closely monitored. All machinery used is fit for purpose with electrical equipment PAT tested and monitored. Our disciplinary and grievance procedures are transparent, and all staff are given a copy of these. They are reviewed annually.

Working conditions meet all Health and Safety regulations and laws to include access to clean welfare facilities, catering arrangements and water accessibility with statutory work breaks observed. Our human resources, quality management and health and safety records and performance are externally monitored as part of our ISO 9001 Quality Management, ISO
14001 Environmental and ISO 45001 Health and Safety certifications.

There is no discrimination in hiring, compensation, access to training, promotion, termination based on race, ethnic or national origin, religion or belief, age, disability, marital status, sex, sexual orientation, gender reassignment, union membership or political affiliation.

All staff are made aware of the signs of human trafficking and invited to report any concerns about this to their line manager or to head office. This may be done confidentially, and all concerns will be treated seriously and investigated. All staff are trained to recognise the signs of human trafficking by receipt of a toolbox talk post recruitment.

We avoid excessive use of fixed term contracts where possible and do not use the apprenticeship scheme where there is no intent to impart skills or to provide regular employment. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or any other forms of intimidation is prohibited within our organisation.

In Summary, we, as far as is possible, ensure that: –
Employment is freely chosen, working conditions are acceptable, no child or forced labour is used in our operations and that this is confirmed as being true of our suppliers. Living wages are paid, working hours are not excessive, no discrimination is practised, regular employment is provided and that no harsh or inhuman treatment is allowed in any part of our organisation.

Miguel Angel Herráiz Marco

Director
Date: 05.02.2025