Last Updated On 14-Nov-2022
Effective Date 14-Nov-2022

​

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 1st September 2022.

Commercial Reclaim Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

 

Organisational structure

Commercial Reclaim Limited has business operations in the United Kingdom.

We operate in the consulting and legal industry sector. The nature of our supply chains is as follows: We work with a few key direct suppliers, who provide us with goods, such as equipment for our premises, office consumables, and services, such as IT software. For more information about the Company, please visit our website: www.commercialrelaim.com

 

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

• Recruitment and selection policy – We seek to prevent modern slavery existing within our own organisation and ensure fairness, equity, and transparency in how we select and compensate employees. We conduct checks on all prospective employees to verify that they are eligible to work in the UK.

• Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.

• Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.

• Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.

We make sure our suppliers are aware of our policies and adhere to the same standards.

 

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• Internal supplier audits.

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.

• Monitor potential risks in our business and supply chains

• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

• Provide protection for whistle-blowers.

 

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping. We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK.

 

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

 

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

• We will train our staff about modern slavery issues and increase awareness within the Company.

 

Training our staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

• How to identify the signs of slavery and human trafficking.

• What initial steps should be taken if slavery or human trafficking is suspected.

• What external help is available.

 

The statement was approved by the board of directors. Paul Sissons, Founder and Director Commercial Reclaim Limited.