Modern Slavery and Human Trafficking Policy

1. Policy Statement

IC Maintenance Services Limited (“the Company”) is committed to acting ethically and with integrity in all its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere in its own business or in its supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. The Company has a zero-tolerance approach to modern slavery in all its forms.

The Company is registered in Scotland (company number SC843715) with its registered office at Unit 74 Albion Business Space, Mitchelston Drive, Kirkcaldy, Fife, KY1 3NB, and carries out maintenance services which may involve work, workers, suppliers and clients in both Scotland and England. This policy therefore reflects the legal framework applicable across Great Britain, and in particular both Scottish and English law.

2. Legal Framework

This policy is informed by, and the Company is committed to complying with, the following legislation:

The Modern Slavery Act 2015: Applies across the United Kingdom in respect of transparency in supply chains (section 54), and creates the criminal offences of slavery, servitude, forced or compulsory labour, and human trafficking as they apply in England and Wales.
The Human Trafficking and Exploitation (Scotland) Act 2015: The principal legislation in Scotland, which consolidates and strengthens the criminal law on human trafficking and exploitation in Scotland, including the offence of human trafficking (section 1) and the offence of slavery, servitude and forced or compulsory labour (section 4). It also provides for Scottish trafficking and exploitation prevention orders and places duties on Scottish public authorities.
The Human Rights Act 1998: Article 4 of the European Convention on Human Rights (prohibition of slavery and forced labour), as given effect in domestic law.
Employment and labour standards legislation: Including the Employment Rights Act 1996, the National Minimum Wage Act 1998, the Working Time Regulations 1998, the Gangmasters (Licensing) Act 2004 and the Employment Agencies Act 1973, which underpin fair treatment of workers.

Where the Company’s turnover meets or exceeds the threshold set under section 54 of the Modern Slavery Act 2015 (currently £36 million), the Company will publish an annual slavery and human trafficking statement. Regardless of whether the Company meets that threshold, it voluntarily commits to the standards of conduct set out in this policy as a matter of good practice.

3. Scope

This policy applies to all persons working for or on behalf of the Company in any capacity, including directors, officers, employees at all levels, workers, agency workers, seconded workers, volunteers, apprentices, agents, contractors, subcontractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and the Company may amend it at any time.

4. Definitions

Slavery: Where ownership rights are exercised over a person.
Servitude: The obligation to provide services imposed by coercion.
Forced or compulsory labour: Work or services exacted from a person under menace of a penalty and which the person has not offered voluntarily.
Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation, whether or not they consent. Under the Human Trafficking and Exploitation (Scotland) Act 2015, exploitation includes slavery, servitude and forced labour, prostitution and sexual exploitation, removal of organs, securing services and benefits by force or deception, and the use of children or vulnerable persons for those purposes.
Indicators of exploitation: Includes situations of debt bondage, withholding of identity documents, withholding or unlawful deduction of wages, excessive recruitment fees, threats against workers or their families, and restrictions on freedom of movement.

5. Responsibilities

5.1 The Board of Directors

The Board has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those under the Company’s control comply with it.

5.2 Managers and supervisors

Managers and supervisors are responsible for ensuring that those reporting to them understand and comply with this policy, for monitoring working conditions on sites under their control, and for escalating any concerns without delay.

5.3 All staff

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains is the responsibility of all those working for the Company or under its control. Staff must avoid any activity that might lead to, or suggest, a breach of this policy, and must notify their manager or a director as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

6. Risk Areas for Our Business

As a maintenance services business, the Company recognises that the construction, facilities management and property maintenance sectors carry an elevated risk of labour exploitation. Particular risk areas include:

Use of subcontracted labour and labour-only subcontractors.
Engagement of agency and temporary workers, particularly at short notice.
Procurement of materials, plant and consumables through extended supply chains.
Cleaning, waste removal, grounds maintenance and other lower-paid ancillary services.
Workers whose first language is not English and who may be less aware of their rights.

The Company will assess these risk areas periodically and target its due diligence accordingly.

7. Due Diligence and Supply Chains

To identify and mitigate risk, the Company will:

Verify the identity and right to work of all employees and workers before they start work, and be alert to indicators such as shared addresses or bank accounts, third parties holding identity documents, or workers appearing withdrawn or coached.
Engage only reputable employment agencies and labour providers, and where applicable check that labour providers hold a valid Gangmasters and Labour Abuse Authority (GLAA) licence.
Require subcontractors and suppliers to confirm their compliance with the Modern Slavery Act 2015 and, where relevant, the Human Trafficking and Exploitation (Scotland) Act 2015, and to accept anti-slavery obligations in their contracts with the Company.
Reserve the right to audit suppliers and subcontractors and to terminate relationships with any organisation found to be involved in modern slavery or which fails to remedy non-compliance.
Pay all employees and workers no less than the National Minimum Wage or National Living Wage, and ensure wages are paid directly to the worker’s own bank account.
Never charge workers recruitment fees, and never withhold identity documents.

8. Reporting Concerns

Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains at the earliest possible stage. Concerns may be raised with a line manager or any director, and will be treated seriously, sensitively and, so far as possible, confidentially. Concerns raised in good faith will be protected in accordance with the Company’s whistleblowing arrangements and the Public Interest Disclosure Act 1998, and no one will suffer any detrimental treatment as a result of reporting a genuine concern.

If a worker is believed to be in immediate danger, the police should be contacted on 999. Other routes for reporting or seeking advice include:

Modern Slavery & Exploitation Helpline: 08000 121 700 (free, 24 hours, UK-wide).
Police Scotland or the relevant police force in England on 101 for non-emergencies.
The Gangmasters and Labour Abuse Authority (GLAA).
Crimestoppers: 0800 555 111 (anonymous).

Potential victims identified in Scotland or England may be referred into the National Referral Mechanism (NRM), the UK-wide framework for identifying and supporting victims of modern slavery. In Scotland, adult victims are additionally entitled to support and assistance under section 9 of the Human Trafficking and Exploitation (Scotland) Act 2015.

9. Training and Communication

Training on this policy, and on the risk the business faces from modern slavery in its operations and supply chains, will be provided to staff as appropriate to their role, with more detailed training for those involved in recruitment, procurement and site management. The Company’s zero-tolerance approach will be communicated to all suppliers, contractors and business partners at the outset of the business relationship and reinforced as appropriate thereafter.

10. Breaches of this Policy

Any employee who breaches this policy may face disciplinary action, up to and including dismissal for gross misconduct. The Company may terminate its relationship with any worker, agency, contractor, subcontractor, supplier or other business partner who breaches this policy or is found to be involved in modern slavery. Where criminal conduct is suspected, the Company will report the matter to Police Scotland, the relevant police force in England, or other appropriate authorities.

11. Monitoring and Review

The Board will review this policy at least annually and following any significant change in the law, the Company’s operations or its supply chains, to ensure it remains effective and up to date. Compliance with this policy will be monitored through routine management oversight, supplier engagement and the investigation of any concerns raised.