Modern Slavery Policy

The purpose of this policy is to specify the details of how Connected Places Catapult (“CPC”) approaches and supports the elimination of modern slavery and meets its obligations under the Modern Slavery Act 2015 (MSA).

Further, this policy outlines our commitment to ensuring that all current and future suppliers meet their obligations under the requirements of the MSA.

This policy has been approved by CLT on August 2022. This policy will be reviewed on an annual basis and where necessary an updated version will be published.

1. What is modern slavery?

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as: slavery, servitude, forced and 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.

2. CPC’s approach

CPC has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships.

CPC is dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or supply chain. Further, it is committed to ensuring there is transparency in its approach to tackling modern slavery throughout the supply chain – consistent with its obligations under the MSA.

CPC expects the same high standards from all of its agents, contractors, sub-contractors, suppliers and their sub-contractors, consultants, third-party representatives and other business partners.

3. Scope

This policy covers all colleagues, including those engaged in duties for the organisation under a letter of authority, secondment contract or work experience/internship; volunteers and any other third party such as contractors who have authority to perform work for or procure goods and services on behalf of CPC.

4. Responsibilities

Procurement Team
The Procurement Team has primary and day-to-day responsibility for ensuring that procurement processes are effective in countering modern slavery, including:

• implementing this policy;
• providing an induction process to new starters within the Procurement Team;
• delivering regular training to relevant people in the business;
• monitoring the use and effectiveness of procurement processes;
• dealing with any queries; and
• auditing internal control systems and procedures.

Management
Management at all levels of CPC are responsible for ensuring those reporting to them understand and comply with this policy and that they are given adequate time to attend training regarding the issue of modern slavery in supply chains as appropriate.

Colleagues
The prevention, detection and reporting of modern slavery in any part of CPC’s business or supply chain is the responsibility of everyone working for or under the control of CPC.

5. Reporting Process

Raise your concerns
If modern slavery is suspected either within CPC’s own business or as part of the supply chain, take one or more of the following actions:

• avoid any further activity that might lead to, or suggest, a breach of this policy;
• raise the concern with your Head of Department or Programme Director at the earliest opportunity; and
• notify the Procurement Team as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

If you are unsure about what constitutes the various forms of modern slavery, please contact the Procurement Team.

Feel safe to raise your concern
CPC is committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicion that modern slavery is, or may be, taking place in any part of the business or its supply chain.

If you do not feel comfortable raising your concern internally, you can raise it with our independent whistleblowing service: SeeHearSpeakUp. Refer to the Whistleblowing Policy for more information.

Zero-tolerance
CPC may terminate its relationship with individuals, suppliers, and organisations if they are deemed to have breached this policy.

6. Communication and Awareness

CPC’s zero-tolerance approach to modern slavery will be adequately communicated to all agents, contractors, suppliers, consultants, third-party representatives, and other business partners and reinforced as appropriate thereafter.

7. Related Policies

Whistleblowing Policy
Disciplinary Policy
Grievance Policy