This Modern Slavery and Human Trafficking Statement sets down Elevate 2 Limited’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational Structure & Supply Chain
This statement covers the business activities of Elevate 2 Limited (Elevate2) which are as follows:
• Implementing business management software and providing services and support for business management software.
The Company currently operates in the following countries:
• United Kingdom
Elevate2 has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Policies and Training
Elevate2 is committed to working ethically and with integrity in all our business relationships. Respect for others and acting with integrity are two of the firm’s key values to which partners and staff are expected to adhere.
The Elevate2 Staff Handbook and Company Policies provide the ethical framework for the decisions Elevate 2 Limited and its people make, individually and collectively. Its guidelines are intended to ensure that everyone within the business behaves in accordance with our values, ethical standards, professional regulations and applicable laws and so helps to maintain Elevate2’s reputation as an ethical and responsible business. The Handbook and Company Policies reinforce the firm’s commitment to the fair and humane treatment of people in our business and our supply chains.
Our recruitment policy refers explicitly to Elevate2’s commitment to fulfilling its obligations under the Modern Slavery Act 2015 (the ‘Act’) and the HR team use a preferred supplier list of reputable recruitment agencies, a condition of inclusion on which is the provision of confirmation that the agencies themselves will not engage in any practice or omit to do any act or thing that amounts to modern slavery as defined under the Act.
Elevate2’s whistleblowing policy expressly refers to slavery and human trafficking and effective systems are in place designed to make it easy for workers to make disclosures without fear of retaliation and to make clear the process to be used should they have any concerns. Partners and staff are openly encouraged to report any concerns relating to activities within our own business, or within Elevate2’s supply chains, regarding slavery or human trafficking.
Elevate2’s expenses policy imposes personal responsibility on partners and staff for ensuring that expenses are only incurred with reputable persons or entities who engage in ethical business practices.
Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved.
Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.
Compliance with the policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager OR a company director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company director OR report it in accordance with our Whistleblowing Policy as soon as possible.
You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current staff handbook.
Communication & awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery and human trafficking must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.