MODERN SLAVERY STATEMENT
This statement is made on behalf of Newlyn PLC pursuant to the section 54(1) of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement.
It outlines the steps we have taken as a business to identify and prevent slavery and human trafficking in our own operations and supply chains. We understand our responsibilities and are committed to improving our practices to combat slavery and human trafficking.
In light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our business or in our supply chain.
Newlyn PLC and Newlyn Contact Centre Services are the largest independent Enforcement and Collections partner to predominantly UK Government and are market leading in the recovery of unpaid council tax, road traffic penalties and non-domestic rates. Newlyn PLC employees are based in the UK. Employee relations are managed consistently across the business. All relevant colleagues are paid at least the UK National Minimum Wage
We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. Our attitude to modern slavery is: zero tolerance.
Newlyn PLC has clear policies in place, they are reviewed and updated on a regular basis. At the heart of these policies is the principle that people are treated with dignity and respect by upholding internationally recognised human rights principles encompassed in the Universal Declaration of Human Rights and the international Labour Organisation’s declaration on Fundamental Principles and Rights at work.
The following internal policies are also in place, or are being developed, to monitor and reduce the risk of modern slavery and human trafficking in our business:
- Supplier Approval Procedure (P006 Supplier Approval Procedure)
- Whistleblowing Policy;
- Financial Crime Policy;
- Health and Safety Policy
- Recruitment Policy
We regularly consider the level of risk of slavery and human trafficking pose to Newlyn PLC, its suppliers, contractors and business partners and given the nature of the companies in our supply chain, we consider this risk is very low.
Over the course of the next financial year, we will continue to enhance our procedures to:
- Prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers and in relation to our own operations.
- Enhance the current training provision to our people
- conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas;
- engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
Newlyn PLC requires all its employees and all its suppliers to immediately report any potential human rights violations and, more specifically, any possible instances of modern slavery or human trafficking. Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting the firstname.lastname@example.org.
Steps for the prevention of modern slavery
Newlyn PLC is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners; our Supplier Code of Conduct specifically contains clauses stating that the provision of services or goods is subject to the supplier complying with all laws relating to ethical sourcing (anti-slavery/human trafficking laws). We expect our suppliers to hold their own suppliers to the same high standards.
Newlyn PLC members have an obligation to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented. Adherence to this policy forms part of all team members’ obligations under the terms of their employment.
It is our intention to maintain existing long-term partnerships with our contractors, suppliers and other businesses with whom the Company has regular ‘face to face’ contact and good operational visibility.
Due Diligence process for Slavery and Human Trafficking
Services procured through third parties are in the process of being grouped into tiers, based on value, importance and risks to Newlyn PLC. This will allow us to identify which of our service providers we should focus the most attention on.
We will be writing to suppliers seeking assurance that the principles of the Act are being followed/adopted, though clearly expecting a more complete and robust attestation from those few suppliers who directly fall under the Act. Where no assurance is forthcoming, we will engage with those parties at contract review to ascertain whether there is sufficient concern to replace them.
Additionally, we expect our suppliers and employees to adhere to the standards set out in the Code of Conduct and Supplier Code of Conduct which reflects our existing commitment to operate ethically and with integrity in all our business relationships. Although Newlyn Plc is unlikely to source products or services from sectors that are at high risk of having Modern Slavery (e.g. farms, in construction, shops, bars, nail bars, car washes or manufacturing), we will monitor our suppliers. Where Gang Labour or contracted services are being used, we will investigate these further and carry out due diligence activities. The implementation and enforcement of effective systems and controls within the organisation and our supply chains will safeguard against slavery and human trafficking.
Risks to Newlyn PLC associated with the Act are managed in accordance with our Risk Management Framework. Additionally, we operate a Whistleblowing Policy and actively encourage the reporting and exposure of unethical behaviour.
Responsibility for this Policy
The Board of Newlyn PLC has overall responsibility for ensuring this policy complies with our legal and ethical obligations. Newlyn PLC encourages all of its employees, consultants, workers, suppliers and contractors to report any concerns they have about slavery and/or human trafficking affecting the business, even if they turn out to be mistaken.
Communication and awareness of this statement
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Following its initial adoption, this Anti-Slavery Statement will be reviewed by the Company’s Board of Directors on a regular basis and may be amended from time to time.