Modern Slavery and Human Trafficking Policy

1. Who this policy applies to

This policy applies to Featherstone Safety Ltd, registered in England and Wales under company number 17410006, registered office 10–16 Tiller Road, London, E14 8PX, and to anyone working for or on behalf of the company, including any employee, contractor, subcontractor, associate or agent.

It is approved by the director and is reviewed at least annually, and whenever the business, its services or its supply chain change materially.

2. Our commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms — slavery, servitude, forced or compulsory labour, and human trafficking — all of which deprive a person of their liberty in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to make sure modern slavery is not taking place anywhere in our own business or in our supply chain.

3. Our business and our supply chain

We are a UK software and health and safety consultancy business. We provide the Featherstone Safety Hub software platform and related consultancy and training services to organisations in the United Kingdom.

Our supply chain is short and consists principally of:

• cloud software and infrastructure providers, listed on our subprocessor page;
• professional services suppliers such as accountants, insurers and legal advisers; and
• occasional subcontractors engaged to deliver consultancy, training or development work.

We do not manufacture goods, we do not operate or contract with overseas production facilities, and we do not use recruitment agencies to source low-skilled or seasonal labour. We consider the risk of modern slavery within our own operations to be low. The residual risk sits mainly with subcontracted labour and with the wider operations of our larger technology suppliers, over which we have limited influence.

4. Steps we take

• Right to work. We verify the identity and right to work in the UK of every person we employ or engage directly, and we keep a record of that check.
• Payment and terms. Everyone working for or with us is paid at or above the statutory minimum for their circumstances, is paid directly into an account in their own name, and is given clear written terms of engagement.
• Supplier and subcontractor requirements. We apply the requirements in section 5 below to suppliers and subcontractors we engage.
• Proportionate due diligence. Before engaging a new subcontractor, and when taking on a new supplier where we set the terms, we consider modern slavery risk as part of our selection. Where a supplier publishes a modern slavery statement or policy, we review it.
• Awareness. The director and anyone engaged by us is made aware of this policy and of how to raise a concern.
• Review. This policy is reviewed at least annually.

5. Requirements for suppliers and subcontractors

The following requirements form part of our standard terms when we engage a supplier or subcontractor. Where a supplier contracts on its own standard terms — as is typically the case with large cloud platform providers — we assess that supplier’s own published modern slavery position instead.

Each supplier and subcontractor must:

• comply with the Modern Slavery Act 2015 and with all other applicable laws on slavery, servitude, forced or compulsory labour, human trafficking and employment;
• not use, and take reasonable steps to ensure that its own suppliers do not use, slavery, servitude, forced or compulsory labour, child labour or human trafficking in any part of its business;
• ensure that all workers engaged in the provision of goods or services to us are working voluntarily, are free to leave their employment, and are not required to lodge identity documents, deposits or fees as a condition of work;
• pay its workers at or above the statutory minimum applicable to them, directly into an account held in the worker’s own name;
• notify us promptly if it becomes aware of any actual or suspected modern slavery in its business or supply chain that relates to goods or services provided to us; and
• provide, on reasonable request, information to allow us to verify compliance with these requirements.

A breach of these requirements is a material breach of the engagement, and we may terminate the engagement with immediate effect.

6. Raising a concern

Anyone who has a concern about modern slavery in our business or supply chain should report it to us at thomas@featherstonesafetyhub.co.uk. We will look into every concern raised, and no one will suffer any detriment for raising a concern honestly and in good faith.

Concerns can also be raised confidentially with the Modern Slavery and Exploitation Helpline on 08000 121 700. Where there is an immediate risk to a person’s safety, call 999.

7. Statutory position

Section 54 of the Modern Slavery Act 2015 requires a commercial organisation with a total annual turnover of £36 million or more to publish an annual slavery and human trafficking statement. Featherstone Safety Ltd is below that threshold and is not required to publish a section 54 statement. We publish this policy voluntarily because we consider it good practice and because our customers and prospective customers ask about it.

This policy is a statement of our own commitments and controls. It is not a warranty about the operations of third parties, and it does not constitute legal advice.