BBFi Public Sector Investigations – Modern Slavery Policy

This Modern Slavery policy was last updated on 24th March 2021

Policy Statement

We have chosen to set our reputation alongside a bold purpose – to shape a vibrant economy building trust and integrity in markets, unlocking sustainable growth in dynamic organisations and creating environments where people and business flourish. Our policy is to assess and address anti-modern slavery laws in our own business and we expect organisations with whom we do business also to adopt and enforce policies to comply with the legislation. Collaboration is at the heart of achieving this with our people, suppliers and clients. Modern slavery is an international crime affecting an estimated 40.3 million slaves around the world. This growing global issue transcends age, gender and ethnicities. It includes victims trafficked from overseas and vulnerable people in the UK who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

Scope

Our turnover is less then £36M therefore we are not bound by the Anti Modern Slavery Act 2015 but we have chosen to implement and comply with the Act as its in keeping with our core values.

When to Use this Policy

This policy provides guidance on all purchasing decisions and the conduct of all suppliers

Policy / Procedure Details

Our policy is to assess and address the risks of violations of anti-human trafficking and anti-modern slavery laws. We adopt procedures that contribute to ensuring modern slavery does not occur in our business or supply chains and we expect organisations with whom we do business to adopt and enforce policies to comply with the legislation.

We ensure:

we seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted
our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.

BBFI only has 30 suppliers across a wide range of sectors, including information technology, marketing, insurance, and facilities management. In addition, the firm works with a number of professionals, consultants, and contractors. Suppliers paid over £30,000 per year make up 89% of our supplier spend and suppliers paid over £50,000 per year 58% of our supplier spend.

Our procedures

We have a number of procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chains.

Employment

Robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 21 and above

Supply Chain

We recognise that we are exposed to greater risk when dealing with suppliers, particularly those who have operations/suppliers outside the UK. The following measures to review and manage this risk are:

an examination of supply chains. We have mapped our supply chains and have identified over 30 suppliers for the financial year 2016-17.
for those whom we pay £50,000 and above (89% of spend), we have mapped those according to location, size and industry, to identify potential indicators of slavery.

Of these:

100% are located within the UK
Non of those suppliers are companies in high risk sectors such as hospitality and leisure, service, retail, construction and food and beverage industries
confirmation by our top suppliers, in terms of spend, of compliance to the Act through their own modern slavery statements
a commitment to collaborate closely with suppliers to help them understand and work towards their own obligations under the Modern Slavery Act
a Responsible Purchasing Policy, which reflects our commitment to and focus on suppliers’ ethical supply chain(s)
a Supplier Code of Conduct, used for all new major suppliers of goods or in re-tendering, clearly stating the firm’s intention to step away (without penalty) if any occurrences of modern slavery is discovered and/or ignored.

Supporting our people

we direct our people to modernslavery.co.uk to provide them with useful information on how to recognise different types of slavery, how to spot the signs and details of a telephone helpline

Supporting our clients

BBFI is continuously looking to support clients with this increasingly important issue, including collaborating with Government agencies and other reputable organisations, to deepen and share knowledge so that we may be impactful by engaging in this area.