Anti-Slavery Policy

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This statement is made pursuant to s.54 of the Modern Slavery Act 2015, and sets out the steps that we have taken and are continuing to take at instaENG to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

instaENG is committed in the strongest possible terms to ensuring our business and supply chain does not employ, support, or enable the practice of modern slavery. This includes slavery, servitude, human trafficking and forced labour. 

In material terms, our zero-tolerance policy means a commitment to acting with ethics, integrity, and transparency across all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

At instaENG there is no place or excuse for involvement in this barbaric practice. We operate with meticulous diligence to preempt any oversights in this regard. 

Our Business

At instaENG Ltd we have produced a truly unique service offering, with a blend of technology and manpower that sets the standard for ACS approved Manned Guarding across our markets that operate exclusively within the UK.

 All our products and services are developed and delivered exclusively with UK sourced staff and technology. Our security manpower is either internally employed, or sourced through ACS approved suppliers - and our technology partners are all UK based. We work with approximately thirty supply partners.  

Our High Risk Areas

We have conducted careful and exhaustive risk analysis, which shows that the only supply market area in which we operate which comes with high risk is the procurement of garments (Security Uniforms). In order to manage this risk, we audit our supply base in line with the ACS standard. Furthermore, we secure anti-slavery statements from providers including explanations of their own risk management approach. 

Our Policies

We back up our unwavering, zero-tolerance position with several internal policies that ensure we conduct business in an ethical and transparent manner. These include:

1. Anti-slavery policy. This policy sets out our stance on modern slavery and explains how our employees can identify any instances of this and where they can go for help.
2. Recruitment policy. We operate a robust recruitment policy, which includes conducting UK work-eligibility checks for all employees to safeguard against human trafficking, and against persons being forced to work against their will.
3. Whistleblowing policy. This policy empowers our employees with the knowledge that they can raise concerns without fear of reprisal. These include concerns about how colleagues are being treated, or practices within our own business or supply chain.
4. Code of business conduct. This code explains how we behave as an organisation, and the standards of behaviour we expect from our employees and suppliers.

Our Suppliers

At instaENG we understand that our integrity in this area is only as good as the suppliers with whom we work. That is why we operate a robust supplier policy, and maintain a preferred supplier list. Suppliers only qualify for the list upon passing a rigorous due diligence process. This includes an online search to ensure that the organisation has never been convicted of offenses relating to modern slavery, and requests for supporting documentation outlining their own policies in respect to working conditions.

Our anti-slavery policy is a non-negotiable part of our supplier contracts, and suppliers are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, we require as part of our contract that suppliers confirm the following:

1. That they have taken steps to eradicate modern slavery within their business;
2. That they hold their own suppliers to account over modern slavery;
3. That they pay their employees at least the national minimum wage and/or national living wage;
4. That we may terminate the contract at any time should any instance of modern slavery come to light.

Our suppliers are a core part of our organization’s ecosystem, and as such we hold them to the same exacting standards of integrity and care as we do ourselves. 

Training

instaENG understands that modern slavery often operates in the shadows. This is why we empower employees within our organization to identify it, and thereby act as custodians of fellow members of our community. We regularly conduct training for our procurement/buying teams so that they understand both the signs of modern slavery, and what to do if they suspect that it is taking place within our supply chain.

Our Performance Indicators

We take active and consistent steps to ensure that any slavery and/or human trafficking taking place within our business or supply chain is identified and reported. Therefore, we trust our system is performing as intended if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval For this Statement

This statement was approved by the Board of Directors on 27/10/2020 signed by Frano Lubura, Quality Manager/General Manager.

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