Section 54 of the Modern Slavery Act 2015 applies to all commercial organisations which carry on business or part of a business in the UK and have a turnover of £36 million or more per annum. Section 54 can therefore apply to non-UK registered companies.

Introduction

This policy ensures that Agricar Ltd complies with section 54 of the , and sets out the responsibilities for employers and employees.

Agricar is committed to ensuring that all of its business operations are free from involvement with slavery or human trafficking.

Annual statement

Agricar will publish an annual slavery and human trafficking statement. A link to this statement will be on the homepage of the website and will be signed and approved by Wendy Smith, Director.

Wendy Smith is responsible for ensuring that this statement is published and reviewed on an annual basis.

The statement will explain the steps that Agricar Ltd has taken to ensure that slavery and trafficking are not taking place in any of its supply chains, or in any part of its own business.

Content of the statement

The following items will be included in the statement.

1. The structure of our organisation, the business operations of the organisation and the supply chains.
2. Our policies in relation to slavery and human trafficking.
3. The due diligence processes that we carry out to ensure that there is no slavery or human trafficking in our business and supply chains.
4. Identification of any parts of our business and supply chains where there is a risk of slavery or human trafficking take place, and the steps that we have taken to assess and manage the risk.
5. An assessment of the effectiveness of the measures that we have taken to stop slavery and human trafficking taking place, and the way that we assess and manage the risks that are identified.
6. A statement that training about slavery and human trafficking is available to all employees.

Additional action points

In addition to producing the annual statement, Agricar Ltd is committed to:

• ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility
• ensuring that any concerns about slavery or human trafficking can be raised through our whistleblowing procedure
• carrying out regular audits to ensure that all our employees are paid at least the National Minimum Wage and have the right to work in the UK
• ensuring that all commercial agreements include an obligation on our suppliers to operate in accordance with the Modern Slavery Act 2015, and to ensure that any of their suppliers and sub-contractors also operate in accordance with the Act
• appointing a named individual to oversee the compliance with the Modern Slavery Act 2015 (this person is Wendy Smith, Director)
• identifying and addressing any areas of high risk in our supply chain
• providing training for all employees who are involved in the supply chain on issues relating to slavery and human trafficking.

Anti-slavery and Human Trafficking Statement 2018

Agricar has six agricultural depots located across the central belt of Scotland. As well as the agricultural side of the business there is an electrical services business located in both Forfar and Brechin that trades as Ness Electrical.

Ness Plant specialises in the complete Manitou product range along with GKD safety systems from both the Brechin and Kinross depots.

We commit to being financially sustainable and to maintaining the highest of ethical standards through continual improvement of process to avoid any potential complicity in human rights violations related to our operations or supply chain.

Exposure to slavery and human trafficking

We have considered the exposure of Agricar Ltd to slavery and human trafficking risk, taking in o account:

• Limited direct and supply chain operations in countries with a high prevalence of modern slavery, informed by third-party external sources including the Global Slavery Index;
• The skills required to undertake the activities and roles across the business, and the skill set and qualifications required to perform these activities, limiting our exposure to temporary or low-skilled agency employment;
• The application of our policies and processes, including procurement and recruitment processes;
• Assessment of any concerns or incidents logged through our whistleblowing reporting process.

As a result of the factors above we consider the risk of slavery or human trafficking occurring within our direct employee population, business operations and tier one supply chain to be low.

Our principles related to slavery and human trafficking

Our commitment to human rights, including our position on forced labour, involuntary labour, child labour, and human trafficking, is outlined in our employment handbook.  

Our principles related to human rights include:

• We are committed to protecting and preserving the rights of our employees, those employed in our supply chain, and those affected by our operations;
• We believe that all employment should be freely chosen and commit to refrain from any form of forced or involuntary labour;
• We are opposed to the use of any form of child labour or practices that inhibit the development of children.

These principles are embedded through a comprehensive collection of employment policies and practice.