Modern Slavery And Human Trafficking Statement

1. About this statement

1.1    This statement sets out Agena Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.

1.2    The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

1.3    The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2. Organisational structure and supply chains

2.1    This statement covers the activities of Agena Group and its associated companies

Countries of operation and supply

2.2    The organisation currently operates in the following countries:

• • • • • England
        • Scotland
        • Wales

Responsibility

2.3    Responsibility for the organisation’s anti-slavery initiatives is as follows:

Policies: Department Heads are responsible for putting in place and reviewing policies and the process by which they were developed.
Risk assessments: Regular meetings of the Board of Directors and/or Senior Managers, have the organisational responsibility for human rights and modern slavery risk analysis. 
Investigations/due diligence: The People Services, Commercial and Finance departments are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operation:

Whistleblowing policy The Group encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Recruitment/Agency workers policy The company 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.
Due diligence

2.4    The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

· mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;

· evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];

·  reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;

·  conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;

·  invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

2.5    The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

·  requiring all supply chain managers/HR professionals to have completed training on modern slavery by 31 March 2023

·  developing a system for supply chain verification whereby the organisation evaluates potential suppliers before they enter the supply chain; and

·  reviewing its existing supply chains, whereby the organisation evaluates all existing suppliers.

Training

2.6    The organisation requires all supply chain managers/HR professionals within the organisation to complete training on modern slavery

2.7    The organisation’s modern slavery training covers:

·  our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;

·   how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

·   how to identify the signs of slavery and human trafficking;

·   what initial steps should be taken if slavery or human trafficking is suspected;

·   how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;

·   what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;

·   what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and

·   what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.