Modern slavery and human trafficking statement
Statement
Introduction
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
Under the 2015 UK Modern Slavery Act, all businesses with over £36m in annual turnover operating in the UK are required to publish a modern slavery and human trafficking statement.
Habitus Collective UK LLP (‘Habitus’, ‘we’, ‘us’ or ‘the Company’) does not meet this threshold, however, as a people-first organisation working with entities who deal with the serious harm that has been caused by slavery, human trafficking and exploitation, Habitus is absolutely committed to preventing slavery and human trafficking in its business activities. We have therefore voluntarily adopted this policy and have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. This also extends to us 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.
This statement sets out Habitus’ 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, nor its supply chains.
Organisational structure and supply chains
This statement covers the activities of Habitus:
The Company is a limited liability partnership registered in England and Wales. The business is a consultancy, working with charities/non-profits, local authorities and parts of the NHS to provide improvements in mental health, community health and wellbeing, community engagement, and peer support.
Our supply chain is formed primarily of large, industry-leading IT firms providing software (SaaS) for us to create, edit, receive and send documentation/materials. These materials are used by the Company’s clients to create, deliver and/or evaluate the projects and programmes that the clients provide for the benefit of their own service users.
Where the Company requires additional capability, it engages members of its pool of freelancers and/or the services of a partner organisation to deliver on the requirements of a tender. Habitus does not work directly with any suppliers which are considered to be particularly vulnerable to human trafficking such as construction, agriculture, manufacturing or hospitality.
Countries of operation and supply
The organisation currently operates in the following countries:
Canada, supporting a national not-for-profit organisation with the design of youth mental health programmes and a large city council with their anti-racism response.
Ireland, evaluating a national charity’s support programme for women affected by prostitution, sex trafficking and other sexual exploitation.
United Kingdom, evaluating a large charity’s systems change programme for children and young people affected by all forms of exploitation, researching the impact of a local authority’s services provision for its marginalised local residents, and supporting the roll-out of a trial programme for a London-based NHS ICS to better connect with the local community it serves.
High-risk activities
Habitus believes that none of its activities are at high risk of slavery or human trafficking.
Nonetheless, the Company is not complacent and recognises that purchasing from suppliers and partnering with organisations on joint bids for tenders significantly raises the risk profile. Details on how this risk is mitigated are listed later in this statement.
Responsibility
Habitus’ Executive Management Team has approved this policy and is committed to making available sufficient resources for its implementation. The Team has overall responsibility for ensuring compliance, as well as day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about this policy 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. Adequate and regular training is given on this policy and the issue of modern slavery in supply chains.
Training
Habitus requires all staff within the organisation to complete training on modern slavery as a module within the organisation's wider ethics training programme, which forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
The Company's modern slavery training covers:
Our business' 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 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.
Awareness-raising programme
As well as training staff, the organisation has raised awareness of modern slavery issues by circulating emails to staff.
The emails explain:
the basic principles of the Modern Slavery Act 2015;
how employers can identify and prevent slavery and human trafficking;
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
what external help is available, for example through the Modern Slavery Helpline.
Policy Application
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, officers, volunteers, interns, agents, contractors, suppliers, 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.
Workers must ensure that they read, understand and comply with this policy.
Relevant underpinning policies
Habitus is a London Living Wage Employer, which means we pay a living wage to our staff and all contractors who work directly for or regularly with us.
Habitus operates the following policies that describe its approach and form part of our approach to mitigating the risks of modern slavery in our business and supply chains.
• Whistleblowing policy – Habitus encourages all its workers, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation as soon as possible. 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. Habitus’ workers (whether employees, officers, consultants, contractors, volunteers or interns), clients, or others who have concerns can contact our Head of Operations and Whistleblowing Officer confidentially by phone or by email to report (at) habituscollective.co.uk
• Procurement code of conduct – Habitus is committed to ensuring that its suppliers adhere to the highest standards of ethics. Purchases are made from large businesses with a published modern slavery and human trafficking statement and for whom the risk of reputational damage from non-compliance outweighs any possible gains. Where organisations partnering with Habitus on a tender or our other suppliers who are not obliged and have not published a statement, we require them to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company asks for said organisations to complete our modern slavery in supply chains questionnaire who works with partner organisations and suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the procurement code of conduct will lead to the termination of the business relationship.
• Recruitment policy – The Company only hires directly and does not use any employment agencies to source labour. We are a Disability Confident Committed employer. All our workers are under the UK’s working time regulations (no opt-outs) and receive pay that is above both the UK and London living wage.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
Likewise, we will immediately terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Nick Androulidakis
Partner, Head of Operations
21st June 2024