Our policy in relation to the Modern Slavery Act 2015
Charles Owen is a very progressive and socially responsible employer.
As part of our internal review of the way in which our business is carried out, we have concluded that we must do all that we can to ensure that our policies and principles are adopted by all of the businesses that we rely upon to deliver our products and services.
The Modern Slavery Act 2015 requires large businesses to set out and publish a slavery and human trafficking statement for each financial year.
MSA 2015 does not apply to Charles Owen as the legislation applies only when the turnover of a business exceeds £36m. Notwithstanding the fact that Charles Owen is exempt from the provisions of MSA 2015, the Board of Directors have determined that Charles Owen will voluntarily apply the principles of the act as if it did apply.
In order to do so, Charles Owen will;
- Communicate with suppliers to make them aware of the provisions of MSA 2015
- Survey suppliers every 6 months in order to establish and to ensure that each supplier is actively applying the provisions of MSA 2015 as far as possible.
The application of the principles set out in the act by Charles Owen is governed by 10 voluntary provisions which represents the due diligence which Charles Owen seeks to instigate in order to apply the provisions of MSA 2015.
To the extent that these provisions are not applied, the Board of Directors will review the position in order to determine whether;
- The supplier will be invited to change by way of improvement or eradication of actions which are at odds with the provisions (a reasonable time frame will be imposed to ensure compliance)
- The supplier relationship will be terminated
Where a specific case of modern slavery as set out in paragraph 12 of MSA 2015, Charles Owen will report the incident to the appropriate authority either in the UK (MS Helpline 0800 0121 700) or in an overseas jurisdiction (Charles Owen will seek legal advice regarding disclosure to an overseas NGO taking into account the influence of the employer with respect to the victim).
CEO Charles Owen
Charles Owen MSA 2015
10 Voluntary Principles
In considering MSA 2015 and its implications, the following 10 principles are integral to our review of organisations that seek to supply products and services to Charles Owen.
These principles are set out in the survey which suppliers are requested to complete and return to Charles Owen.
Additional notes explaining the relevance of the principles are set out below each principle. The terms of reference of each principle are not governed exclusively by the notes. The notes are for general guidance only.
The Employee is free to choose whether he or she wishes to be employed by the Employer
Employees are not bound (formally or informally) to the employer and are therefore free to leave their employer with reasonable notice.
The employee and employees overall are free to bargain with their employer individually or collectively
Workers have the right to engage with their employer either individually or collectively.
The workplace environment is safe and hygienic
Safe and hygienic requires the absence of hazard, adequate toilet facilities and the provision of water.
Child labour is not used
UK law recognises a child up to the age of 18.
However, children can be employed from age 16.
In other jurisdictions adulthood is recognised at younger ages.
If a child, or children, is / are employed, details should be provided whereupon research will be carried out to ensure they are legally employable and that the terms of their employment are reasonable.
Living Wages are paid
UK law enforces minimum / living wage rates.
Other jurisdictions may impose alternative rates.
Whether there are de minimis values to apply or otherwise, the wages rate payable must be justified by reference to comparable alternative local employment.
Working hours are not excessive
UK law requires that employees do not work more than 48 hours per week.
Other jurisdictions may impose alternative terms.
Whether there are de minimis values to apply or otherwise, working hours must be justified by reference to comparable alternative local employment.
No discrimination is practised
In relation to hiring, termination or rates of pay, discrimination must not be applied by reference to race, religion, sex or age.
Regular employment is practised
Employment must not be subject to practices which seek to avoid employment obligations by the use of unreasonable or disreputable contractual practices.
Harsh or inhumane treatment is prohibited
Abuse, physical or otherwise, threatening behaviour, harassment or intimidation is forbidden.
Suppliers apply these principles in relation to the relationships they have with their own suppliers
Suppliers seek to regulate the relationship they have with their own suppliers by applying the Charles Owen principles as far as possible.