Modern slavery policy
Introduction
Jurassic Fibre Limited (“we”, “us”) are committed to improving our practices to combat modern slavery in our business by taking steps, as far as we are able, to ensure that our supply chains are free from slavery and human trafficking. This statement sets out the steps that we have taken in the previous financial year to understand potential modern slavery risks within our business structure and supply chain, and as well as the steps taken to eradicate these risks.
We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff members are expected to report concerns, using the appropriate reporting channel, as set out in our Whistleblowing Policy, and Directors are expected to act on any concerns raised.
About us
We are a business that is focussed on the construction of an ultrafast fibre-to-the-premises (“FTTP”) network in the UK, and the provision of ultrafast broadband to homes and businesses within the network area.
Our annual turnover is under £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement:
- to show our commitment to ethical trading principles.
- to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.
Our supply chains mainly consist of contracted construction crews, and the provision of networking cable and ancillary goods.
To whom does this policy apply?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency works, seconded workers, volunteers, interns, apprentices, agents, contractors, external consultants, third-party representatives and business partners.
Our commitment to ethical trading
We are committed to ethical trading principles and to acquiring goods and services without harm to others.
Due diligence and risk assessment
To help identify and monitor the risk of slavery and human trafficking in our supply chain we ask all our contractors and suppliers are required to comply with our ethical policies and, in particular:
- provide us with evidence of their compliance with the Modern Slavery Act 2015.
- provide employees with good working conditions, fair treatment and reasonable rates of pay.
- respect workers’ human rights and comply fully with all applicable laws.
We will include a provision in our procurement processes and contractual documents to include obligations on suppliers to comply with the Modern Slavery Act, conduct regular Modern Slavery risk assessments within their own supply chains, implement appropriate controls to prevent Modern Slavery and notify us immediately if they become aware of any Modern Slavery within their supply chains. Suppliers who breach these obligations will face appropriate actions which could include termination of contract.
We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies).
Effectiveness in combating slavery and human trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
- the percentage of suppliers and sub-contractors vetted for ethical labour practices.
- the number of inspections of direct suppliers and sub-contractors in our supply chains in the past year.
- the number of reported breaches in the past year.
- percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.
Training
We provide employees and management with training on a range of compliance matters which would include their obligations under the Modern Slavery Act 2015, particularly in relation to mitigating risks within supply chains.