Overview
PDMS recognises that its role as a corporate entity, both on the Isle of Man and in the United Kingdom, goes beyond offering employees worthwhile careers, providing clients with the best technological solutions, and delivering increasing value to stakeholders. It also acknowledges its responsibilities to the wider community, and this policy demonstrates PDMS’ commitment to safeguarding potential victims of modern slavery and human trafficking.
Slavery & Human Trafficking Legislation
This requires businesses to declare the activities and actions that they have taken during the financial year to safeguard that modern slavery is not taking place in the workplace. PDMS is fully committed to playing its part in eradicating modern slavery and firmly believes in transparency and collaboration in the supply chain to eliminate the risks of modern slavery.
At the heart of PDMS’ approach to human rights are several pieces of legislation including:
- Modern Slavery Act 2015
- Human Trafficking and Exploitation (Scotland) Act 2015
and several important, internationally recognised declarations, standards and codes:
- Global Slavery Index 2016
- The UN Universal Declaration of Human Rights
- The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
- The UN Global Guiding Principles on Business and Human Rights
- The UN Global Compact
- The Base Code of the Ethical Trading Initiative
These documents combined are the foundation for how and where PDMS work and provide reference to best practice advice. The Company strategy for the prevention of human trafficking and modern slavery is supported by internal policies and is strengthened by the supplier approval processes.
Our Approach
PDMS has a zero-tolerance approach to any form of modern slavery and is committed to acting ethically and with integrity and transparency in all its business dealings. Modern slavery is commonly understood to include activities such as servitude, forced labour, forced or servile marriage, the sale and exploitation of children, and debt bondage.
There are a number of policies in place to ensure that human rights are not being denied to individuals within PDMS, whether intentional or not. Through these policies the Company ensures that all legal requirements are followed when recruiting new staff, and that potential employees have the legal right to work from either the Isle of Man or UK.
In order to safeguard against any form of modern slavery taking place within the supply chain, PDMS has put effective controls and verifications in place, as per its related supplier approval procedure. These requirements are communicated to suppliers and clearly enforced.
PDMS operates a whistleblowing policy, which means that if you have any concerns about the way any of your colleagues are being treated, or any other practices within the business or supply chain, you can raise your concerns without fear of repercussions or reprisal. Any breaches of PDMS’ policies will be taken very seriously and could result in dismissal for gross misconduct. In some cases where serious misconduct has taken place, they will be reported to the relevant law enforcement agency.
Approved Suppliers
PDMS has a relatively diverse supplier base, and as such recognises its role as supply chain leader and a resulting influencer in the global efforts to eradicate modern slavery and human trafficking.
Potential suppliers must be thoroughly checked, prior to providing goods or services to the business, before they can be included on the PDMS approved supplier list. At the very least, suppliers must demonstrate their commitment to not participating in modern slavery (whether adults or children), and this also extends to holding their own suppliers to the same standards. If the supplier fails to meet the standards set out in the supplier approval process, they will not gain authorisation for the supplier list and/or the relationship will be terminated.
Due Diligence Process Cycle - Five Stages
- Establish a broad perspective beyond the immediate business, including key suppliers
- Determine priorities based on areas of highest risk and review accordingly
- Identify the process of avoiding or mitigating risk
- Define method for rectifying abuses and remediating any victims
- Develop learning strategy allowing us to evolve processes and procedures
PDMS reviews all service providers and suppliers every two years to allow them to identify those with the highest potential risk of modern slavery. This is based on evolving risk in the sector of supply and location, their contract type, the level of skill involved by the service provider.
Effectiveness of Approach
PDMS understands it must always remain vigilant to identify and address any issues associated with slavery and human trafficking in its business and throughout its supply chains. The Company is committed to continuing to enhance its ability to identify, prevent and mitigate ant actual or potential risks in these areas.
Where it is considered necessary the Company may audit its suppliers’ provision and will continue to raise awareness within its business in respect to modern slavery and have identified escalation points for staff to raise concerns or suspected breaches of Company policies.