Modern Slavery Policy

Modern Slavery encompasses many different types of behaviour and abuse, perpetrated against individuals from any background and of any age. Modern Slavery is abuse and therefore is included in the SDDE Smith Group Safeguarding Policies and Procedures.

The following pieces of legislation are relevant to this procedure:

Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Island) 2015; Modern Slavery Act 2015; Criminal Justice (Scotland) Act 2003: Asylum and Immigration (Treatment of Claimants, etc) Act 2004: Criminal Justice and Licensing (Scotland) Act 2010.


What are the different types of abuse that come under Modern Slavery?

  • Slavery, servitude and forced or compulsory labour.
  • Human Trafficking (the purpose of movement of a person for exploitation in whatever form). There is no minimum or maximum distance, it can be from one room to another. 


What can Exploitation include?

In addition to the above:

  • Sexual exploitation, i.e. forced into prostitution, regardless of age of the individual being exploited.
  • Removal of organs.
  • Securing services by force, threats or deception, in particular if the individual being exploited is a child or an adult at risk. This can also include an individual being forced into committing criminal acts against their will as a possible debt-bondage process.


Our Commitment

The SDDE Smith Group is committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Modern Slavery Act in any part of our organisation.

The SDDE Smith Group welcomes transparency as encouraged by the Modern Slavery Act and this policy sets out for the public, our stakeholders, suppliers and employees the steps we are taking in this regard.



At the point of recruitment, appropriate checks in accordance with relevant laws are carried out on prospective employees and our People Team works closely with the relevant teams in the local areas to make sure that pay and conditions are appropriately managed.

In accordance with our commitment to acting ethically and with integrity in all our business relationships, we intend to implement effective systems and controls to ensure Modern Slavery is not taking place in our supply chains. This will involve ensuring the effective communication and reinforcement of relevant policies, which give a clear view of the values and principles that underpin all our work and that we expect all persons involved in our business and supply chain to adhere to. These policies comprise of the SDDE Smith Group Code of Conduct and Diversity and Inclusion Policy  


Indicators of Modern Slavery

Child Sexual Exploitation is a named type of abuse in its own right. This is the specific targeting of children (anyone under the age of 18) in order to exploit them sexually. Typically this occurs when gangs or perpetrators, who may use drugs, alcohol and/or gifts to groom the child. It is important to note that with all the cases of sexual exploitation, a child is unable to consent to their own abuse.

Indicators of modern slavery include:

  • Individuals not being paid for the work they undertake.
  • Individuals being in debt-bondage (being told they “still” owe money after having paid off a previous debt).
  • An individual’s passport being held by their “employer” in order to keep the individual at work.
  • Multiple benefit claimants having their benefits being paid into the same account.
  • An individual not having freedom of movement (i.e. passport being taken).
  • Clear exploitation of an individual by another for financial or sexual gain.

Under the Modern Slavery Act 2015, we are required to ensure we do not have any aspect of modern slavery within our business and supply chain. As such, we have to issue a statement, published on our website, which clearly reflects this and the actions we have taken, in order address this.


Responding to concerns about modern slavery

If any staff member of volunteer within the SDDE Smith Group has any suspicions or concerns that any aspect of modern slavery may be occurring, the must take appropriate actions. Relevant procedures for doing this are detail below:

  • Concern is identified, this could be a colleague is a victim or perpetrator, or a third party informs us of a concern they have.
  • Staff member discusses this with their line manager (where appropriate) and the Group People Manager immediately.

Please note, if an individual is, or a group of people are, in immediate risk of danger or harm, the police must be immediately notified on 999.    


Next Steps

According to the nature of the concern, the Group People Manger will lead on the next actions that are to be taken. This will be on a case by case basis. Next steps could include:

  • Notifying the police.
  • Contacting the Modern Slavery helpline (0800 0121 700)
  • With the individual’s consent, completing a referral to the National Referral Mechanism (NRM), national framework for identifying potential victim of human trafficking and modern slavery and providing appropriate are.
  • Referral to external agency.

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