“Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour. This can then be considered under five headings:
“Human trafficking” involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child-related crimes, forced marriage and illegal adoption.
Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK and in Ireland who are forced to work illegally against their will across many different sectors.
It has been estimated that globally modern slavery generates as much as $150bn (£116bn) in profits every year with more than a third of these profits generated in developed countries, including the UK and the Republic of Ireland.
Our policy
To conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws.
If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. We review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.
We are committed to acting professionally and with integrity in all its business dealings and relationships whether all over UK or abroad.
In this context, Potru Ltd has created a dedicated Anti-Slavery and Human Trafficking Policy.
We will review this policy and its operation in practice, at least on an annual basis.
Reporting knowledge or suspicion of slavery or human trafficking:
All employees and partners within the firm have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the relevant Engagement Partner and to the Head of Risk, who will decide what further action, if any, is deemed necessary. If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report is to be submitted to the Money Laundering Reporting Officer (MLRO). In addition, our Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or human trafficking.
Partners and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.
These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.
Employment procedures
Certain procedures are in place pertaining to our employment practices.
Supply chain/ Procurement
We recognise that every business is exposed to greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However, Potru Ltd considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. In addition, our supply chains are primarily confined to the UK, a relatively lower risk of modern day slavery and human trafficking.
From a risk management perspective, we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern-day slavery and human trafficking. We developed measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor take-on review and ongoing monitoring process, which is handled by the Legal team.
This review and monitoring process is to take into account the relevant risk factors the (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector guidance (with reference to the Appendix of the Anti-Slavery and Human Trafficking Policy).
Looking forward
We will continue to develop and implement the measures mentioned above in respect of our supply chain.
Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2021 and beyond.