Modern Slavery Act

We are passionate about caring for our people and are proud to be part of the communities in which they live. Our responsibility goes far beyond that of just providing people with work and we consider it our duty to ensure all of our colleagues, their families and our partners are provided safe and welcoming environments in which they work.

At BIWAD Ghana we understand the impact of  Modern slavery and are committed to play our part in tackling this very real issue. We are always mindful that this could be happening to any one of our colleagues, their families or within our supply chain and it is our responsibility to ensure we provide safe and confidential ways in which they feel they can talk to us should they need to.

The following statement sets out our commitments and approach in dealing with Modern Slavery and Human Trafficking.

Our policies to mitigate the risk of Modern Slavery

We have an Anti-Slavery Policy, which sets out our zero-tolerance stance on slavery and human trafficking, as well as providing our employees with guidance on how to identify and report slavery concerns, if necessary, using the separate Whistleblowing Policy. Our Code of Conduct sets out the labour, social and environmental standards that we expect of our suppliers and their sub-contractors, subsidiaries and own suppliers. BIWAD Ghana and our suppliers ensure there is no slavery, forced labour or human trafficking in our business or at any stage of our supply chain. All new suppliers are requested to adhere to our Code of Conduct and, as set out below, we ask certain suppliers to report on this through the Code of Conduct Questionnaire, as part of our due diligence process.

How we identify and manage risks

Recruitment

Our recruitment processes ensure that not only are we and the customers we serve safe and legal; we can use the checks we do as a safeguarding process for our colleagues.

All our people undergo identity and Right to Work checks prior to commencing employment. We also carry out reference checking and, where applicable, police records checks. We employ our people directly with checks in place to ensure that payment of salary is made directly to that person.

In addition, we carry out Right to Work checks bi-annually for all colleagues, either through our own assessment or one carried out in conjunction with our client.

Our Recruitment Procedure outlines the mandatory requirements which includes the requirement to use approved agencies in the recruitment process. Our On-Boarding Procedure seeks to ensure that third party providers can demonstrate that they comply with all legal requirements, including the requirement to comply with the Modern Slavery Policy.

Training

We continue to strengthen employee awareness of our stance on slavery and human trafficking. We have updated our guidance for our suppliers, adding details of plans for managing the risk within our supply chain. This complements the training created for our own people, so they understand the issues involved, become more aware of the risks, the signs to be vigilant of and how to raise awareness should they see or fear something suspicious.

We believe that improved awareness is one of our most effective methods to reduce the risk of modern slavery and with the help of both our employees and suppliers we aim to ensure that there are no opportunities to hide forced labour within our organisation or our supply chain.

We are taking a targeted approach to more detailed training on slavery and human trafficking (either by way of workshop training or an e-learning module, as appropriate). This will cover our people involved in our procurement processes and the hiring of staff, especially where this involves the promotion and monitoring or our agency workers.

We will re-train all our line managers throughout 2020 in the awareness of Modern Slavery and HumanTrafficking.

Business and supply chain risk assessment and risk management within our Supply Chain. Our supply chain includes sub-contractors, suppliers and labour agencies. Our Supplier Code of Conduct reflects our longstanding commitment to ensuring that we act ethically and with integrity in all of our business relationships, supported by continuous development and implementation of effective systems and controls. As part of our due diligence checks when on-boarding new suppliers we require that they sign up to and adhere to the Code of Conduct including ensuring that they conduct business within all applicable laws and regulations and that they make proper provision for the health, safety and wellbeing of all employees, visitors and customers.

• . Supplier Code of Conduct – The business is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

As part of our commitment to ensure that we do not have any slavery or forced labour in our supply chain we commit to a yearly review all of our processes and seek to engage with a third party who could assess the effectiveness of our policies and processes so we are continuing to deliver on the commitments made.

Within our sub-contractor supply chain

Our Supply Chain also includes the use of Labour Providers. The company seeks to have minimal use throughout the business as it is recognised that this can potentially pose a risk to the business. We also recognise that we can minimise the risk to our business by directly employing staff on permanent terms and conditions. Any Agency Labour provider use must be authorised by Procurement and allrelevant due diligence documents must be provided for review by the relevant teams prior to supply of labour.

Recruitment/Agency workers policy – The business uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. All Agencies who supply temporary labour into our business will be audited a minimum of once a year.