1. Introduction and Key Points
Intraguard Limited is committed to high standards in our business and this policy is intended to help the suppliers of equipment, goods and services to the company and its clients understand their obligation to ensure legal, ethical and steps they need to take to protect children and to ensure compliance with the International Labour Organisations Conventions 138 and 182 relating to Child Labour, and the UK Modern Slavery Act 2015. Our suppliers will also ensure they comply with any laws and regulations related to employment.
The Company is committed to the highest standards of honesty, transparency, probity, integrity and accountability and expects all suppliers of services or supply of goods to be responsible for the implementation of this policy.
2. Company’s position
- We work in accordance with all Human Rights legislation and expect suppliers to do the same. This will include no child labour, forced labour, threat of violence, harassment, intimidation, debt bondage, bonded labour.
- Child Workers (below a minimum age of employment, or 15 years if this higher) must not be involved in the manufacture or supply of goods and provision of services to the company.
- Children (under 15) must not be permitted in production areas.
- Adequate precautions are put in place to protect Young Workers, who are permitted to legally work, i.e. about the minimum age of employment of 15 and below the age of 18.
- Children are more vulnerable than adults to exploitation so proper recruitment methods must be in place.
- If Child Labour is found in a part of our company’s supply chain, we commit to continuing the business relationship with the supplier as long as no legal breaches have been made. We are willing to work with the supplier to identify solutions in the best interest of the child to ensure no detriment to the health and education to that child.
- Should a supplier not cooperate with this Policy, we will communicate with the supplier and we reserve the right to end the business relationship should there be no agreed remediation plan.
- In extreme cases, order and payments may be put on hold until the situation is resolved.
- We support formal work-based training or apprenticeship programs that enable Young Workers to learn new skills. In the UK we also encourage School Work Experience Programmes, and, in such cases, we undertake a Risk Assessment.
3. Supplier Responsibilities
- We expect all suppliers of services or goods to monitor their own supply chains and to inform Intraguard Limited immediately if they have any concerns regarding Child Labour and Young Persons.
- Provision of identify and verification of any person working on our or client premises carrying out work as a representative of the company, this is for security measures and identity purposes.
- Suppliers must have robust systems in place to prevent Child Labour, this will include; identifying the authenticity of employees, recording and maintaining a list of employees detailing their name, date of birth, date of joining, location of work, ID documents.
- Collate a list of all Young Workers, if any are employed.
- Young Workers can be employed, provided they do not perform hazardous work and there are adequate precautions to protect them while carrying out non-hazardous work. Full training to be provided and they must be paid at least the relevant minimum wage. The supplier must conduct risk assessments to identify any hazardous work or conditions and put systems in place to ensure protection is given.
4. SUPPLIERS ACTIONS
- Review their suppliers or manufacturing businesses, whether direct or indirect to ensure compliance with this policy and legislation.
In cases where Child Labour is identified the supplier must:
- Immediately inform the company.
- Collate a list of all Children, Young Workers and countries (where applicable).
- Explain the legal requirements and restrictions on working ages to the Child and assure that they may be employed when they reach legal age and at the correct location of work.
- Identify and understand the Child’s/Young Workers situation and advise the company of the remediation programme that is in the best interests of the Child/Young Worker.
- Prevent the Child from working and where appropriate ensure the living conditions are provided and assist them financially so the Child does not find work elsewhere until they are of legal working age.
- Document all actions and maintain records such as financial and payslips.
- Maintain copies of all employee records including ID and ages.
- Develop an age screening procedure to prevent recurrence.
- Must not threatened the Child/Young Worker, family or hamper the process agreed.
- Suppliers must act honestly and with integrity and records can be reviewed.
- Find relevant local organisations to assist with finding a solution that is in the best interest of the Child.
- In the case of Young Workers if it is found that they are undertaking hazardous work or working in a dangerous environment, the person must be removed, and measures put in place to ensure the Young Workers can do work safely. Wages should continue to be paid in such instances until a resolution is found.
5. Reporting and Compliance
- The supplier must report any matter in relation to this policy to the relevant Divisional Manager or Director and to the Company’s Compliance Manager.
- The supplier will authorise the Company or nominated third party representatives to engage in monitoring/auditing to confirm compliance with this policy and procedure. The company understands that certain records are protected by the General Protection Data Regulations.