Introduction from the Managing Director
Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns, and management are expected to act upon them.
Modern slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including servitude, forced or 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. This document sets out the policy of tmgroup with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term ‘modern slavery’ has the meaning given in the Act.
As tmgroup has an annual turnover in excess of £36m, we are required by the Modern Slavery Act 2015 to provide a statement of intent to all of our employees and suppliers.
tmgroup comprises of IT (Development, Infrastructure and Service Desk), Operations, Finance, Sales and Marketing and HR.
Our Supply Chains
Our supply chain includes obtaining property searches from Local Authorities and other professional Search providers, outsourced payroll, office stationery providers, IT Vendors, recruitment consultants, site maintenance contractors, cleaning contractors, external storage, kitchen supplies and waste disposal.
Our Policies on Slavery and Human Trafficking
Our Anti-Slavery statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due Diligence Process on Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk:
- we have two offices, tmgroup in Swindon and PSS in Glasgow, with senior managers based at both sites to ensure optimum control of the work environment
- where possible, we build long standing relationships with local suppliers and customers and make clear our expectations of business behaviour
- with regards to national or international supply chains, our point of contact is preferably with a UK company or branch, and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain
- whistleblowing procedure –the Company’s Whistleblowing Policy is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner. The Whistleblowing Policy applies to all employees and may be found on the Company’s intranet site
Supplier Adherence to our Values
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values. The SMT and all managers are responsible for compliance in their respective departments and for their supplier relationships.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
Our Effectiveness in combatting Slavery and Human Trafficking
We communicate with the next link in the supply chain and monitor their understanding of, and compliance with, our expectations to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year