DH Clamp Consulting Ltd (DHC) leads a network of consultants who provide up to date risk and predictive analysis to global organisations, who often operate in high risk areas.
S. 54(1) of the Modern Slavery Act 2015 requires all businesses operating within the UK with an annual turnover exceeding £36 million to produce a statement outlining what steps, if any, the business has taken to prevent slavery and human trafficking from taking place within their organisation or their supply chain. Although DHC has a turnover below £36 million, we work with larger organisations subject to the Act and we seek to comply with the Act.
DHC is committed to ensuring that slavery and human trafficking are not taking place in our employed or voluntary workforce, nor in our supply chain. Our defintions of modern slavery are set out in Appendix 1.
We take the following precautions to prevent these injustices:
· We ensure that all employees have a legal right to work in the UK, or in the relevant overseas country, are paid a fair and legal wage, and are under no duress;
· We ensure that all contacts or suppliers are provided with basic expenses, and are under no duress;
· We ask all major suppliers (those who go through our standard procurement procedures - transactions above £600, or above £5,000 if in the UK) to sign a declaration that they have protections and due diligence procedures in place to prevent slavery and human trafficking within their organisation or supply chains.
Any incidence of non-compliance we discover will be dealt with on a case-by-case basis, notifying the proper authorities where appropriate.
If an existing supplier were to be suspected of having links to involvement in modern slavery, interaction with that supplier would immediately cease.
This statement was approved by DHC’s Directors in January 2022. It will be reviewed on an annual basis and revised when necessary.
Appendix 1 - Modern slavery definitions
Source: Modern slavery in supply chains by the CIPS and Walk Free Foundation https://www.cips.org/Documents/About%20CIPS/Ethics/CIPS_ModernSlavery_Broch_WEB.pdf
Trafficking
Recruitment, transportation, transfer, harbouring or receipt of persons.
By means of threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person (these means are not required in the case of children).
With the intent of exploiting that person through:
Prostitution of others;
Sexual exploitation;
Forced labour;
Slavery (or similar practices);
Servitude; or
Removal of organs.
(UN Trafficking Protocol, 2000)
Slavery
The status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised. Includes slavery-like practices; debt bondage, forced or servile marriage, sale or exploitation of children (including in armed conflict) and descent-based slavery.
Forced labour
All work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself or herself voluntarily.
(ILO Forced Labour Convention, 1930 (no.29))
High Risk Categories
The risks of modern slavery are most pronounced:
• where workers have fewer protections through inadequate laws and regulations, weak or non-existent enforcement, and poor business and government accountability;
• where there is widespread discrimination against certain types of workers (e.g. women and ethnic minority groups);
• where there is widespread use of migrant workers;
• in conflict zones; and
• in some specific high-risk industries (typically industries involving raw materials).
Last Update by DHC’s Directors: January 2022