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This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Nuneaton Harriers Community Association Ltd ("We") has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Nuneaton Harriers Community Association Ltd ("We") have a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Nuneaton Harriers Community Association Ltd ("We") have over 10 years of experience in delivering leisure management contracts on behalf of Nuneaton & Bedworth Borough Council.

We engage with a wide variety of organisations for the delivery of a broad range of goods and services.
Our supply chain partners vary in size and structure from very small locally sourced suppliers or contractors to large national corporate institutions.

We encourage smaller businesses to join our supply chain as this accords with our desires to bring social and environmental benefits to the local community in which we operate.

We are conscious that there are commercial, legal and safety related advantages to using suppliers who are able demonstrate compliance and competence and seeks to use external suppliers who share our values to maintain consistency of standards.

Where new suppliers are engaged they must successfully complete the Everyone Active approved suppliers process. Our broad assessment criteria include checks of the following:

  • Insurances

  • Health & Safety documentation including Policy, Procedures, Risk Assessment and Method Statements

  • Current quality accreditations or certifications e.g. ISO 9001, ISO 14001, OHSAS18001, CHAS IIP etc.

  • Supplier credentials including qualifications, training and competency

  • Customer references

  • Details of any prosecutions, or notices for improvement

Contracts are in place with many of our corporate suppliers. As part of the contract review process we are introducing a contractual requirement for suppliers that they do not engage in any activity that is contrary to the Modern Slavery Act. Over time we will achieve the inclusion of the contractual requirement in all supplier relationships.

We will achieve these aims through our initiatives to identify and mitigate risk in the following ways (but not limited to):

  • More stringent vetting of our supply chain through our approved supplier process and performance reviews;

  • Continually review our practices for checking that all employees and apprentices are paid at least the minimum wage and have a right to work;

  • Encourage the reporting of concerns and the protection of whistle blowers;

  • Will not knowingly support or deal with any business involved in modern slavery practices or human trafficking

  • Have zero tolerance to slavery and human trafficking through colleague understanding of risks in our business, providing guidance to relevant managers and colleagues on the need to avoid those risks and possible indicators of them in the supply chain.

  • Briefing Directors and senior managers on the risks and how these may arise within the business or supply chain.

We have reviewed our existing policies and procedures to ensure that we are conducting business in an ethical and transparent manner. The processes that we consider give us control in avoiding modern slavery or human trafficking under the act within our business are:

  • Recruitment and Selection Procedure including guidance for the Prevention of Illegal working

  • Equal Opportunities Policy

  • Job offer Terms and Conditions of Employment

  • Grievance Procedure

  • Managing Payroll Cost Procedures

  • New suppliers – companies procedure

  • New suppliers – self-employed procedure

  • Right to Work policy

  • Equality and Diversity Policy

  • Whistleblowing policy

  • Colleague Guide

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