Modern Slavery Act
Introduction
Modern Slavery And Human Trafficking Transparency Statement
Venator Executive is committed to taking appropriate and proportionate steps to ensuring acts of modern-day slavery and human trafficking do not exist within its business and supply chains.This statement is issued by Venator Executive under the provisions of the Modern Slavery Act 2015 (the Act).This statement has been approved by the Board of Directors and signed by Paul Murphy, the Managing Director. The information contained in this statement is correct at the date of publishing.
Policies:
Venator Executive is committed to acting ethically and ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.
The Company’s internal policies reflect our commitment in all our business relationships to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
All internal policies are reviewed regularly to ensure they are appropriate, well communicated and promote continued compliance with the Act and other applicable legislation.
The following key policies are in place which relate to the controls relevant to the prevention of slavery and human trafficking in our operations:
Modern Slavery& Human Trafficking Policy
This has been introduced in May 2021 and reaffirms our commitment to tackling MS and setting out the standards expected of all employees.
Whistleblowing Policy
Venator Executive encourage all employees to report any concerns related to the activities of the business, including any worries in relation to modern slavery and human trafficking. Venator Risk’s whistleblowing policy and procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially.
Other relevant Venator Executive policies include:
Equality &Diversity Policy
Venator Executive is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination, harassment, and victimisation on the grounds of race, sex, pregnancy, maternity, martial or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.
Ethics and Business Integrity Policy
This policy outlines Venator Executive’s requirements for conducting business to the highest ethical standards. Venator Executive demonstrates a clear approach to business integrity and ethics, which underlies the Company’s values.·
Group Recruitment Policy
Venator Executive ensures that the process of recruiting employees is fair, consistent, professional and non-discriminatory to both internal and external candidates.
Our commitment – what we do
Supply Chain Adherence To The Venator Values And Ethics
Venator Executive considers its supply chain to be at a ‘low risk’ in relation to slavery and human trafficking. Given the nature of the business and how we operate within the sectors within which we work, there is no significant utilisation of overseas or unskilled labour, being key areas identified as posing a higher risk; imports are of a minimal amount, unskilled labour is of a small quantity, and where used, we predominantly engage with reputable companies on long terms contracts , and operations of our and our associated companies are UK or EU based meaning suppliers are already under an obligation to comply with UK and EU law on forced labour.
Supplier Adherence
Venator Executive demonstrates a zero-tolerance to modern slavery and human trafficking and reserves its rights to terminate any arrangements with any of its suppliers should any modern slavery or human trafficking offence be committed or suspected. Venator Executive will update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.
Effectiveness In Combating Modern Slavery And Human Trafficking
Any suspected incidence of slavery or human trafficking within Venator Executive or its supply chain would be immediately reported to the Board of Directors in the first instance. It would then be dealt with appropriately, which may include, but is not limited to, terminating commercial relationships, disciplinary action and notifying the relevant authorities.
What We Will Do In 2024/2025
As part of our on-going commitment to ensuring modern slavery and human trafficking is not present within Venator Executive Limited, we will look to take the following action in 2024/2025:·
Continue to raise awareness amongst employees of modern slavery and human trafficking issues.
Following on from the review of standard supplier Terms and Conditions, continue a further review of our full suite of precedent contracts and terms to ensure all partners, stakeholders, and counter-parties that we contract with, as applicable, are required to adhere to our relevant policies.
As our business continues to grow and we engage with more long-term partners, work collaboratively to ensure a consistent best practice model is adopted for tackling these issues and ensuring and maintaining compliance.
Develop an expanded third-party due diligence process to apply to strategic opportunities across Venator Executive to foster a standardised and consistent approach to modern slavery and human trafficking compliance across all acquisitions and investments across the various business units.
COVID-19
Taking into consideration the nature of Venator Executive’s operations, including within its supply chain, it is not considered that the impact of COVID-19 has created any heightened risk of modern slavery occurring within the business or its supply chain. However, as the wider social and economic impact of this pandemic are known Venator Executive will be monitoring its supply chain more closely in this regard and continues to adopt a zero-tolerance approach to any actual or risk or modern slavery within its supply chain and business.
Measuring our Effectiveness
We recognise that modern slavery and human trafficking is a global and increasing challenge for businesses and we are committed to an ongoing action plan to develop our approach and monitor its effectiveness. To do this we will continue to:
Review the effectiveness of our Modern Slavery and Trafficking Policy and the Supplier Code of Conduct;
Ensure all colleagues review our policy annually and confirm they have read and understood it;
Ensure our supply chain remains under constant review; and
Continue to monitor any cases reported via our Whistleblowing Policy. Overall, Venator Executive will continue to focus on understanding further our supply chains, identifying risk areas and increasing awareness amongst employees on the issues of modern slavery and human trafficking and the reporting procedures available to them. We will continue to update policies and procedures as required to ensure appropriate safeguards against any mistreatment of persons are in place.
Venator Executive March 2024
Venator Executive is a trading style of Venator Staffing Limited
Registered in England and Wales with Company Number: 11624200
VAT Number: 383 5642 79
Registered Office:48 – 52 Penny Lane Mossley Hill, Liverpool, Merseyside, United Kingdom, L18 1DG
