MODERN SLAVERY STATEMENT & POLICY
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Cube International Group has a zero-tolerance approach to modern slavery, and 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 ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also 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 of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This Modern Anti-Slavery Policy and Statement is intended to cover our business conduct in all countries and territories.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the policy
Cube International Group Chief Executive Officer has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Managing Directors of each company within Cube International Group have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
All employees of Cube International Group are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to their respective Managing Director.
Examples of Modern Slavery
Modern Slavery can take many forms. For the purposes of this policy following list of examples serve to identify typical situations that indicate a person or persons may be vulnerable to Modern Slavery. It is not an exhaustive list:
- Forced Labour – Where people are forced to work against their will and or there is a threat of punishment.
- Human Trafficking – Where people are taken against their will to another location in order to carry out work. This differs from people smuggling as once the person arrives they continue to be exploited and do not have the freedom to move or work at their own free will.
- Debt Bondage – This is the most common form of modern-day slavery and occurs where an individual is forced to work in order to meet the terms of debt repayment.
- Child Labour & Slavery – Child labour is harmful to children because it keeps them from getting an education and hinders their social and emotional development. Child Slavery – Is when a child is used purely for someone else’s commercial gain.
- Employee Exploitation – Gang Masters / employers who provide labour to as part of the supply chain and who control the working hours, conditions and rates of pay provided to their employed labourers. Labourers can be exploited by being paid substantially below the legal minimum wage, working in dangerous or harmful conditions, and or work for periods far greater than the legal limit. Often the labourers are also subject to Human Trafficking and are unaware of their individual rights as an employee. Though exploitation can also take place within the labourer’s own country.
Supply Chain Management
Those with procurement and supply chain management within the business shall ensure appropriate measures are in place to mitigate against the risk of Cube International Group companies entering into contracts which increase the risk of Modern Slavery occurring. Typical measures may include:
- Using suppliers who are approved by and or signatories to organisations which certify and or promote ethical and responsible resourcing such as Sedex.
- Ensuring suppliers are able to provide a Modern Slavery statement
- Undertake supplier audits and ongoing monitoring
Employee Compliance with the policy
Employees of Cube International Group must ensure that they have read, understand and are able to comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
- Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
- Employees must notify your line manager OR a company Managing Director as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
- Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
- If an employee believes or suspecst a breach of this policy has occurred or that it may occur, they must notify their line manager or company Managing Director OR report it in accordance with the Whistleblowing Policy as soon as possible.
- Employees should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
- If Employees are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with their line manager or company Managing Director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Communication & awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. 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.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Review & Monitoring
Managing Directors are required to provide an annual statement of compliance in relation to this policy. This statement will be received and acknowledged by the Cube International Group Chief Executive Officer. The policy shall be reviewed annually or sooner if so required.
Cube International Group Chief Executive Officer
3 December 2020