Modern Slavery and Human Trafficking Policy
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.
This policy details the robust activities PDMS undertake with regard to Modern Slavery and Human Trafficking, and will communicate the safeguards in place to make sure that PDMS, through collaboration with its supply chain, does not partake in any activities that participate in, or facilitate modern slavery and human trafficking.
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. PDMS understands that it has responsibilities to the wider community. This policy demonstrates the Company’s commitment to the safeguarding of potential victims of modern slavery and human trafficking.
Slavery and Human Trafficking Legislation
The UK’s Slavery and Human trafficking legislation 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 work place. 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
Combined, these documents, are the foundations for how and where PDMS works 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.
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.
PDMS operates a number of policies that aim to ensure that it is not denying human rights to individuals, whether unintentionally or not, within its business. Through HR policies the Company ensures that it adheres to all legal requirements regarding the recruitment of new staff and that all potential employees have the legal right to work from the applicable office (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 it’s related supplier approval procedure. These requirements are communicated to suppliers and clearly enforced.
Furthermore, the Company operates a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within the business or supply chain, without fear of reprisals.
The Company will treat any breach of its policies very seriously and any serious breaches of this policy could result in dismissal for gross misconduct and /or require the Company to report those activities to the relevant law enforcement agencies.
With a relatively diverse supplier base, PDMS recognises its role as supply chain leader and a resulting influencer in the global efforts to eradicate modern slavery and human trafficking. To this end, it maintains an approved supplier list, entry to which is subject to thorough due diligence.
The Company requires its suppliers to be approved by PDMS prior to providing goods or services to the business. This includes, at the very least, a commitment to not participating in modern slavery (whether adults or children). This commitment places an expectation upon the supplier to hold their own suppliers to the same standards. Any failure by a supplier to meet the standards set out in the supplier approval process will result in not progressing with the supplier approval and/or the termination of the relationship.
Due Diligence Process
The due diligence process cycle has five stages:
PDMS reviews all its service providers/suppliers every two years and this allows the Company 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 Approaches
PDMS recognises the importance of maintaining constant vigilance in order 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 capacity to identify, prevent and mitigate any actual or potential risks in these areas.
Where deemed necessary, PDMS may undertake audits of its suppliers’ provisions and will continue to raise awareness within its business with respect to modern slavery and have identified escalation points for staff to raise concerns or suspected breaches of Company policies.