MODERN SLAVERY STATEMENT

Modern slavery statement for financial year 2018 – 2019

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that SJA Group Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. SJA has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in 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.

Our business

As a facilities company working within high end properties in central London we are continually reviewing our policies and procedures to safe guard our staff. One of the ways we do this is to closely work with the trade unions to ensure the highest possible conditions for our staff and service partners.

Our high risk areas

All people employed by SJA Group are required to produce ID Documents to include Right to work in the UK, where applicable, on joining the company. In addition to this, if required by our clients, we also carry out relevant DBS (disclosure and Barring Service) checks for individuals.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
  2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
  4. Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our suppliers

SJA operate a supplier policy and maintain a preferred supplier list.  We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This due diligence includes an online search to ensure that particular organisations have never been convicted of offenses relating to modern slavery and on-site audits which include a review of working conditions.  Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that –

  1. They have taken steps to eradicate modern slavery within their business
  2. They hold their own suppliers to account over modern slavery
  3. They pay their employees at least the national minimum wage / national living wage (as appropriate)
  4. For international suppliers, they pay their employees any prevailing minimum wage applicable within their country of operations
  5. We may terminate the contract at any time should any instances of modern slavery come to light

Approval for this statement

This statement was approved by the Board of Directors on 14th December 2017.

ADRIAN DEANE