Modern Slavery & Human Trafficking Policy

Draft for review. Items in [square brackets] need confirming before this policy is signed off.

Our commitment

LaunchPad Manufacturing has zero tolerance of modern slavery and human trafficking. We will not knowingly work with anyone involved in it, and we take steps to make sure it is not happening in our business or among the labour providers and suppliers we use.

Our turnover is below the threshold at which the Modern Slavery Act 2015 requires a published annual statement. We have this policy because it is the right thing to do and because our clients expect it.

What modern slavery is

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It often looks like ordinary work: people are controlled through debt, threats, withheld documents or wages, or by someone else who takes their pay.

How we prevent it

• Right-to-work and identity checks are carried out on everyone before they start, including agency workers.
• We never charge anyone a fee for a job, and we check that our labour providers do not either.
• We never hold anyone’s passport or identity documents; we take copies for our records only.
• Wages are paid directly into a bank account in the worker’s own name. We look into shared bank accounts, addresses or phone numbers.
• Terms of employment are explained in a language the worker understands.
• Labour providers are vetted and checked under our Responsible Recruitment Policy, and our agreements with them require compliance with this policy.
• Managers and supervisors are trained to spot the signs.

Signs we look out for

• Someone else always speaks for the worker, collects them or holds their documents.
• The worker seems afraid, withdrawn or unsure of their address or employer.
• They have debts to a recruiter or landlord, or no access to their own wages.
• They work unusually long hours, or several workers share one address, bank account or phone.

Reporting a concern

Anyone who suspects modern slavery should report it straight away through our confidential reporting system (it can be anonymous), tell [name, role], or follow our Whistleblowing & Grievance Policy. You can also call the Modern Slavery & Exploitation Helpline on 08000 121 700. If someone is in immediate danger, call 999.

Concerns are treated in confidence, and no one will suffer for raising one in good faith.

Responsibility and review

This policy applies to everyone who works for or on behalf of LaunchPad Manufacturing, and the labour providers and suppliers we use. It is owned by [name, role] and has the full support of the directors.

We review it at least once a year, and sooner if the law or the way we work changes. Everyone it applies to is told about it at induction and when it changes.

Signed: [name], [director], LaunchPad Manufacturing. Date: [date].