MODERN SLAVERY ACT 2015
ERA Modern Slavery – Anti-Slavery and Human Trafficking Statement
Company Overview
We are an international organisation. We do things differently by treating our employees, as well as our clients and candidates, with care and respect. Our employees are located mainly in the UK.
Our Policy
We are committed to delivering high standards of corporate governance and a key component of this is managing our business in a socially responsible way. We employ the highest ethical and professional standards and comply with regulations and laws applicable to our business. To date, we have not been made aware of or discovered any incidents relating to modern slavery within our business or through our candidate placements. However, as a business, we are committed to continually striving to ensure that any mistreatment of individuals is identified and eradicated in each division of our business and our candidate placement.
Future Actions
Going forward we hope to continue to raise awareness of modern slavery in the following ways:
Completing staff training on slavery and human trafficking.
Request further information on the business practises of our current and future clients and partners, and in particular, seek to obtain information on how they identify risks of modern slavery within their businesses and what actions they would take should they identify activities relating to modern slavery. We will measure our performance against the actions and steps identified in this statement and identify further areas of improvement to add to our annual compliance risk management.
This statement is made in accordance with the Modern Slavery Act 2015 section 54 (1) and constitutes drjamestalbot.com’s modern slavery statement for the financial year ending 1st of April 2024. drjamestalbot.com is one of the world’s leading consultancy practices. As professional consultants, it’s important for us to put on record our commitment to corporate social responsibility. We believe transparency through our supply chain is the best way we can reassure the public that we are doing our best as an ethical corporate citizen.
In that spirit, we have published here our annual statement addressing the abhorrent issues of slavery and human trafficking, which have no place in modern business. This statement is made in compliance with section 54 of the Modern Slavery Act 2015 and explains the steps we are currently taking or will take within this year to prevent modern slavery and human trafficking within our business – and that of our clients. We have taken the following key steps to ensure slavery and human trafficking do not occur within our supply chain or those of our clients.
Identifying and addressing risks
We and all our employees and our independent specialists are employed under formal contracts that are fully compliant with UK law. We make limited use of external suppliers.
The risks associated with modern slavery and human trafficking within our own organisation and immediate supply chain are small. The principal risks are all professional i.e. the advice that we give to our clients on their purchasing practices and on their supply chains. These risks will vary from sector to sector and from client to client, so it is essential that we set in place a robust policy aimed at protecting our clients and ourselves from contributing in any way to these heinous crimes. Where we do make use of external suppliers we will apply the same policy in the interaction with our own suppliers as we are adopting for our clients.
Developing policy
We have developed our ‘Modern Slavery: Policy and Revised Practice for Associates’ to cover our role as professional advisers. Since July 2017, all new projects undertaken by drjamestalbot.com and its associates have been compliant with the policy. Our view is that all organisations should be compliant with the provisions of the Modern Slavery Act and provide a policy statement, whether obligated to under the turnover requirement or not.
The principles by which this policy will be implemented are as follows:
- Where the client has their own Modern Slavery Statement and policy, we will ensure that these are incorporated into our dealings with suppliers. We will be requesting that the suppliers confirm their Modern Slavery Statement to us, and provide written confirmation that their supply chain is compliant with our Client’s Modern Slavery policy.
- Where the client has no Modern Slavery statement we will offer a generic statement and policy for the client to use.
- Clients will always have the final say as to whether or not they are happy with the supplier’s approach to compliance with the Modern Slavery policy.
- If the client does not want the generic Modern Slavery Statement and policy included on their behalf we still will require that the supplier accept the policy as part of the tender requirements.
- Where the terms of the purchasing arrangement are covered by a legal agreement (a formal contract), relevant wording concerning compliance with the Modern Slavery Act will be included.
Training
A key part of our slavery and human trafficking strategy is to promote cultural change within both our employees and clients through awareness training. This year we:
- Ran a training and awareness session for all employees and Associates
- Provided everyone with their own copy of the Modern Slavery Policy
- Updated all our training and template material to incorporate the new provisions and make them available to new staff
- Established an escalation route for associates to request further support on behalf of their clients.
- Developed a service for clients to assist with the completion of their own modern slavery statements.