Overview and how we define Modern Slavery
Modern slavery and human trafficking are serious crimes and a violation of human rights that affect communities and individuals across the globe. There are various forms of this modern slavery, which deprives victims of their liberty and usually involves financial exploitation. Connex strictly prohibits the use of forced labour and human trafficking in all of its operations and global supply chains.
The following statement is made pursuant to s.54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement, our adherence to the Act, and highlights the steps we take to ensure that there are no occurrences of modern slavery or human trafficking within the organisation or its supply chains.
Connex has a zero tolerance to any form of modern slavery in any part of our activities. We are committed to acting with integrity and transparency, ethically and with respect to fundamental human rights. We are fully committed to the prevention of all forms of slavery, forced labour or servitude, child labour and human trafficking, both in our business and in our supply chains.
We recognise that without a robust and thorough approach to tackling modern slavery, there is a risk that human trafficking may occur within various areas of our business including procurement, our supply chain and employment.
Due Diligence Processes
Connex operates a procurement management policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier.
At the outset of our business relationship we require that they confirm to us that:
They have taken steps to eradicate modern slavery within their business.
They hold their own suppliers to account over modern slavery
(For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate), conduct right to work in the UK checks on all employees and that they have appropriate policies in place to tackle modern slavery
(For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations and that they regularly monitor and review the working conditions of their employees.
We have a zero tolerance approach to any form of modern slavery and we may terminate our business relationships at any time should any instances of modern slavery come to light. As highlighted in our Supplier Code of Conduct, it is a fundamental policy of ours to conduct our business with honesty, integrity and in accordance with the highest ethical standards. We are committed to the ongoing review of our practices to ensure we continue to meet the requirements of the Act.
Risk Assessment and Management
The prevention, detection and reporting of modern slavery and human trafficking, in any part of our business or supply chains, is the responsibility of all Connex employees, individuals or businesses under our control.
The Risk and Compliance department as well as Heads of function are required to be familiar with all aspects of the current regulatory regime and guidance, as well as keeping abreast of new legislation and regulatory regime changes, as well as ensuring that:
Regulatory and legislative changes are reviewed and any necessary amendments communicated to, and/or implemented within the relevant business areas.
Compliance policies and processes are reviewed annually, or (where applicable), on an ad-hoc basis where there are relevant regulatory/legislative changes.
An effective risk management framework is implemented across the business.
Any identified risk exposure is identified and mitigated.
We also encourage openness and support to anyone who raises genuine concerns in good faith and to ensure no one suffers any detrimental treatment as a result of reporting suspicions of modern slavery or human trafficking in whatever form, may be taking place in any part of our own business, or in any of our supply chains.
Risk Assessment and Management
We assess the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain by:
Monitoring the risks in the sectors that we operate in and reviewing our operations and policies in light of any increased risks.
Monitoring the training provided to staff
Reviewing our grievance procedures and whistle-blowing procedures to ensure that adequate measures are in place to support, encourage and protect employees.
Regularly monitoring our business relationships with our suppliers and ensuring that they continue to have adequate measures in place to combat modern slavery.
Monitoring any reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified in our business and/or our supply chain.
Our grievance and whistleblowing policies have been reviewed in the last 12 months to ensure they are comprehensive. Employee wellbeing initiatives are encouraged and we provide ongoing support to employees, helping us to further protect them. We continue to audit our suppliers, ensuring they have adequate measures in place to combat modern slavery.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to management and supervisory staff so that they are aware and understand the signs of modern slavery so they know what to do if they suspect that it is taking place within our business or supply chain.
Listed below are some of the warning signs that could indicate people being kept in servitude or are being trapped in a forced labour situation.
Abuse of vulnerability
Deception
Restriction of movement
Isolation
Physical and sexual violence
Intimidation and threats
Retention of identity documents
Withholding of wages
Debt bondage
Abusive working and living conditions
Excessive overtime
The presence of a single indicator in a given situation may in some cases imply the existence of forced labour. However, in other cases you may need to look for several indicators which, taken together, point to a forced labour case. Overall, the set of eleven indicators covers the main possible elements of a forced labour situation, and hence provides the basis to assess whether or not an individual worker is a victim of this crime.
Our Policies
We operate a number of policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Recruitment & Selection Policy
Whistleblowing Policy
Equal Opportunities Policy (incorporating anti bullying and harassment)
Supplier Code of Conduct
All policies are available by contacting our HR department.
Key Areas of Focus in 25/26
The process of risk based approach, review and improvement is a continual one for Connex and we will maintain this approach to ensure that these policies not only remain appropriate, but also help us identify and prevent any risk of modern slavery or human trafficking penetrating our organisation or supply chain.
The key areas of focus for Connex are:
Equality of all employees; gender equality; wage equality; and promotion of diversity
Strengthened supplier engagement, working together with our supply chain to carry out ethical audits, to identify any areas of concern to mitigate risk.
Continue to upskill our management and stakeholders, but also extend training to all employees.