Modern Slavery and Human Trafficking Policy
The Laminar Group recognises that modern slavery and human trafficking are a violation of fundamental human rights and are contrary to the Modern Slavery Act 2015 (the “Act”). The Laminar Group takes a zero-tolerance approach to non-compliance with this Policy and will not tolerate any slavery or human trafficking in any part of its business.
Laminar Group will take steps to ensure that modern slavery and human trafficking are not taking place in its business. This will be achieved by ensuring that:
- All recruitment is carried out in a fair and transparent manner and will comply with relevant legislation and standards.
- Suppliers will be expected to comply with the Immigration, Asylum and Nationality Act 2006.
- Laminar will train appropriate staff to understand the risks and issues surrounding modern slavery and human trafficking, how to identify it and appropriate measures to prevent it.
1. Organisational Structure, Business, and Supply Chains
- a. Organizational Structure: The Laminar Group comprises three main departments: Operations, Sales & Marketing, and Human Resources. Each department reports directly to the CEO. This structure ensures efficient communication and accountability in enforcing the modern slavery policy across all levels of the organisation.
- b. Business Activities: The Laminar Group is a leading consulting firm specializing in providing strategic advisory services, project management, and operational excellence solutions. We operate primarily in sectors such as construction, energy, and technology, assisting organisations in optimising their performance and achieving sustainable growth.
- c. Supply Chains: We recognise that the consulting sector may present risks related to labour practices, particularly concerning subcontracted services and independent consultants. As such, where these services are required, we implement enhanced due diligence to ensure compliance with our modern slavery policy. This includes regular assessments of ethical labour practices and adherence to our standards.
2. Policies on Slavery and Human Trafficking
- a. Zero Tolerance Policy: The Laminar Group has a zero-tolerance policy towards modern slavery and human trafficking. Any instance of such activity within our operations or supply chains will be subject to disciplinary action and potential legal consequences. This aligns with our commitment to complying with the Modern Slavery Act 2015, promoting ethical practices throughout our supply chains.
- b. Human Rights Policy: Our Human Rights Policy explicitly prohibits modern slavery and human trafficking. This policy is regularly reviewed to align with international human rights standards and frameworks.
- c. Vendor Code of Conduct: Our Vendor Code of Conduct requires suppliers to adhere to our standards and comply with all relevant anti-slavery and human trafficking legislation, including the Immigration, Asylum and Nationality Act 2006. Contracts with suppliers will include explicit clauses that prohibit modern slavery and human trafficking practices.
3. Due Diligence Processes
- a. Risk Assessment: We employ a tiered approach to risk assessment that includes Initial Screening, Risk Matrix evaluation, In-Depth Due Diligence for high-risk suppliers, and Ongoing Monitoring. This ensures proactive identification and management of potential modern slavery risks within our operations and supply chains.
- b. Supplier Screening: We screen potential suppliers using self-assessment questionnaires, including our Due Diligence Questionnaire, to gather detailed information on their labor practices. We also review publicly available information on ethical practices and obtain third-party due diligence reports for high-risk suppliers. Existing suppliers are monitored through ongoing engagement, audits, and periodic reviews to ensure compliance with our standards.
- c. Monitoring and Reporting: We have established mechanisms for reporting potential violations of our modern slavery policy, which include a confidential reporting system accessible to all employees and suppliers. Concerns may be reported directly to the Laminar Group Board of Directors for further investigation.
4. High-Risk Areas and Risk Management
- a. High-Risk Areas: Specific areas identified as high-risk include manufacturing, where labor conditions may vary significantly, and global supply chains that may rely on temporary or migrant workers. Our risk assessment findings will guide our approach in managing these high-risk areas.
- b. Risk Mitigation: For each identified high-risk area, we implement tailored measures to mitigate risks. These include enhanced supplier due diligence, stronger contracts with explicit anti-slavery clauses, regular monitoring and audits, and comprehensive training for employees involved in supply chain management to recognise and respond to potential risks.
5. Effectiveness Measurement
- a. Performance Indicators: We will measure the effectiveness of our efforts to combat modern slavery through the following indicators:
- Number of supplier audits conducted.
- Number of supplier training sessions completed.
- Number of reported incidents and their resolution.
- Number of suppliers screened for compliance.
- Percentage of suppliers with anti-slavery clauses in contracts.
- b. Regular Review: We conduct a comprehensive review of our policy, processes, and performance indicators regularly to ensure their continued effectiveness and alignment with best practices.
6. Training and Capacity Building
- Employee Training: We provide annual training to our employees on modern slavery, including identifying red flags, understanding the implications of modern slavery in consulting and procurement, and the appropriate procedures for reporting any concerns. This training is delivered through a combination of e-learning modules and interactive workshops, targeting all employees across the organisation. Managers and team leaders receive additional specialised training focused on risk assessment, supplier management, and the implementation of our modern slavery policy.
