Modern Slavery
Modular Clean Air Ltd. is committed to ensuring that there is no modern slavery, human trafficking, or illegal workers in our business or our supply chains. This statement affirms our intention to act ethically in our business relationships. Slavery, child labour, and human trafficking are serious crimes and a violation of fundamental human rights. There are various forms of this “Modern Slavery” which deprive victims of their liberty and usually involve financial exploitation.
The Company conducts its business fairly, ethically, and with respect to fundamental human rights. We are fully committed to the prevention of all forms of slavery, forced labour or servitude, child labour, and human trafficking, both in our business and in our supply chains. We will not tolerate it.
This statement sets down the company’s commitment to preventing slavery, human trafficking, and illegal workers in our business activities, and the steps we have put in place with the aim of ensuring that there is no slavery, human trafficking, or illegal workers 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.
You are required to read and comply with this policy if you work for, or on behalf of, the Company in any capacity including as an employee, director, officer, worker, consultant, volunteer, supplier, or service provider.
The Operations Manager is responsible for this policy. Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and the Company. It could also involve other legal steps being taken against you.
1.1. Preventing Slavery and Human Trafficking in Our Business
The Company makes appropriate checks on all employees, recruitment agencies, and suppliers to know who is working for, or on behalf of, us.
The Company provides every employee with a written contract of employment and pays every employee in accordance with the law.
We comply with our legal obligations to ensure the health and safety of all our employees and workers, including in relation to working hours, rest breaks, and holidays.
All employees are required to acknowledge receipt of this handbook to show they have read and understood it. It is accessible to all employees and workers.
1.2. If You Are One of Our Suppliers
If you supply the Company with goods or services, you must assess your business and supply chains and confirm to the Operations Manager that you comply with your legal obligations in relation to Modern Slavery, and are committed to ensuring there is no slavery, forced labour or servitude, child labour, or human trafficking taking place in your business or any of your supply chains.
If you breach this policy or are found to have slavery or human trafficking in your business, or knowingly in your supply chain, the Company may terminate the contract with you and pursue its legal remedies against you.
1.3. If You Are an Employee or Worker Providing Services for Us
You must immediately report any suspicions of Modern Slavery or human trafficking in our business or supply chains to the Operations Manager. They will investigate, within a reasonable time, any actions which may be required to be taken.
You will not suffer any detrimental treatment because of reporting any genuine concerns, raised in good faith, under this policy. This applies even if, after investigation, the concerns are found to be mistaken.
If you believe that you have suffered any such treatment, you should immediately inform the Operations Manager, and if you are an employee, refer to our Grievance and Whistleblowing Policies.
2. Training
To ensure a good understanding of the risks of modern slavery, human trafficking, and illegal workers in our business and supply chains, the Company requires all employees to attend a short training presentation. The company modern slavery training presentation is delivered within the first two months of employment.
3. Illegal Workers
Modular Clean Air Ltd. carries out appropriate VISA, Passport, and Date of Birth checks to ensure all employees are entitled to work in the UK, in accordance with Sections 15 to 25 of the Illegal Migration Act 2023 and the Immigration, Asylum and Nationality Act 2006.
Should any individual subject to UK right-to-work checks apply to work with us (as identified by pre-employment screening questions), a copy of their work visa and passport would be required.
All necessary checks will then be made to ensure the person has the right to work in the UK and that they have no immigration restrictions that prevent them from doing the work in question.
Should a potential employee’s right to work in the UK be on a temporary basis, additional checks will be carried out to ensure that their documents have been renewed prior to them commencing employment, to prevent a situation where their working rights would expire during their period of employment.
All related verified documentation is retained for a minimum of three years after the individual has ceased employment with Modular Clean Air Ltd.
4. Due Diligence Processes for Slavery and Human Trafficking
Modular Clean Air Ltd. undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers.
The Company’s due diligence process includes:
Building long-standing relationships with suppliers and making clear our expectations of business partners.
Evaluating the modern slavery and human trafficking risks of each new supplier.
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.