ORGANISATIONAL STRUCTURE

  1. The organisational structure of the Peninsula Group of Companies comprises Peninsula Business Services Limited and several associated companies in the United Kingdom, Republic of Ireland, Australia and New Zealand including Peninsula Business Services (Ireland) Limited, Bright HR Limited, Health Assured Limited, Croner Group Ltd, Croner TaxWise Limited and Employsure Pty Limited.
  2. The Group is controlled by a Board of Directors. The Group’s Head Office is located in Manchester, with other offices located in Hinckley, Glasgow, Belfast, Dublin, Sydney and Auckland.
  3. The Group is predominately involved in the provision of business and legal services to other businesses in both telephone, email and face to face consultancy formats. It offers a 24-hour advisory service for which demand is consistent throughout the year.

DEFINITIONS

The Group considers that modern slavery encompasses:

  1. Human trafficking;
  2. Forced work, through mental or physical threat;
  3. Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  4. Being dehumanised, treated as a commodity or being bought or sold as property;
  5. Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

  1. The Group acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.
  2. The Group has a zero tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
  3. The labour supplied to the Group in pursuance of the services it provides is carried out wholly in the countries where those services are provided i.e. United Kingdom, Republic of Ireland, Australia and New Zealand as appropriate.
  4. No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, Republic of Ireland, Australia and New Zealand as appropriate, and in many cases exceeds those minimums in relation to its employees.

 POTENTIAL EXPOSURE

  1. The Group considers its exposure to modern slavery to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
  2. In the operation of its business, the Group’s main supply chains are those related to the provision of services. The Group considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains.

STEPS

  1. The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains.
  2. The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.
  3. In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has contacted (or attempted to contact) all first tier suppliers to set out our zero tolerance stance on modern slavery and to ensure that slavery and/or human trafficking is not taking place.
  4. The Group has taken action to monitor reports of modern slavery and will cross reference such reports with our first tier supply chain. The Group will seek to discontinue business with any first tier supplier found by the enforcement authorities to be involved in modern slavery.
  5. The Group encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

ASSESSMENT OF EFFECTIVENESS IN COMBATTING MODERN SLAVERY

To ensure effectiveness in combatting modern slavery, the Group maintains an accurate supplier list including contact details.  It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.

POLICIES

The Group also a Corporate Social Responsibility Policy which further defines its stance on modern slavery. In addition, a Whistleblowing policy is in place which encourages the reporting of any wrongdoing which is in the public interest.

GROUP COMPLIANCE MANAGER

The Group has a Group Compliance Officer, to whom all concerns regarding modern slavery should be addressed. The Group Compliance Manager will undertake an annual review of the Group’s obligations towards eradicating modern slavery within its organisation and supply chains.

The Group also provides training on awareness of modern slavery to those within the organisation who have been identified as having responsibilities in this regard.

REVIEW                                                          

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to all companies within and associated to The Peninsula Group (“the Group”). It will be reviewed for each financial year.

This statement relates to the 2015/2016 financial year and is approved by:

Peter Swift, Group Finance Director

Alan Price, Group Operations Director