Policy Commitment
Ganymede has a zero-tolerance approach to all forms of modern slavery, and we are committed to acting legally, ethically and with integrity in all our business dealings and relationships. We seek to adopt and develop a proactive approach to prevent and remediate the risks of modern slavery, forced and debt-bonded labour, human trafficking and hidden exploitation within our workforce.
We expect all who have, or seek to have, a business relationship with Ganymede to familiarise themselves with this policy and to act at all times in a way that is consistent with its values.
This policy will be used to underpin and inform any statement on Slavery and Human Trafficking that we or our Parent Company RTC Group PLC produce further to the
transparency in supply chain requirements of Section 54 of the Modern Slavery Act (MSA) 2015.
Scope of this Policy
This policy applies to all persons working for or on behalf of Ganymede in any capacity, including employees, directors, officers, workers, contractors, consultants, and Ganymede’s supply chain. This policy will be reviewed by the Managing Director at least once a year. This policy does not give contractual rights to individuals and we reserve the right to alter any of its terms at any time, although we will notify applicable parties of any changes. Any updated versions will be made available to all employees and notified to persons covered by the scope of the policy.
What do we mean by Modern Slavery?
Modern slavery can take many forms. It is a complex and multi-faceted crime and therefore it is important to understand what we mean by modern slavery. Detailed
below are important definitions that everyone should understand:
Modern slavery is a is a broad term used to encompass offences that involve one person depriving another person of their liberty, to exploit them for personal or commercial gain.
Forced labour is all work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered themselves voluntarily.
Debt-bonded labour is where a person’s labour is demanded as a means of repayment for a loan or service.
Human trafficking is the recruitment and transportation of persons by threat, force, coercion or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.
Hidden labour exploitation is action up to and including modern slavery which involves the exploitation of workers and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or labour provider.
Other forms of slavery, which we will not tolerate, but are not specifically referenced in the MSA 2015 include, but are not limited to:
Child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.
All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspects of our business and business relationships.
Indicators of Forced Labour
The International Labour Organisation’s (ILO) 11 indicators of force labour are intended to help us to identify persons who are possibly trapped in a forced labour situation, and who may require urgent assistance. The indicators represent the most common signs or “clues” that point to the possible existence of a forced labour case.
Abuse of vulnerability is when an employer takes advantage of a worker’s vulnerable position, such as those with a lack of knowledge of the local language or laws, those with limited livelihood options, those belong to a minority religious or ethnic group or those who have a disability or have other characteristics that set them apart from the majority population.
Deception is when individuals are recruited with promises of decent, well-paid jobs. But once they begin working, the promised conditions of work do not materialize, and workers find themselves trapped in abusive conditions without the ability to escape.
Restriction of movement is when workers are not free to enter and exit the work premises, without being subject to certain restrictions. This could include workers having their movements controlled inside the workplace, through the use of surveillance cameras or guards, and outside the workplace by agents of their employer who accompany them when they leave the site.
Isolation is when victims of forced labour are isolated in remote locations, denied contact with the outside world. This could include being kept behind closed doors or having their mobile phones or other means of communication confiscated.
Physical and sexual violence is when workers, their family members and close associates are subjected to actual physical or sexual harm. This can include being forced to take drugs or alcohol, undertake inappropriate tasks that were not part of the initial agreement, or kidnapping and being held captive.
Intimidation and threats are used when workers complain about their conditions or wish to quit their jobs such as threats of physical violence, denunciation to the immigration authorities, loss of wages or access to housing, further worsening of working conditions or withdrawal of “privileges” such as the right to leave the workplace.
Retention of identity documents is when an employer retains identity documents or other valuable personal possessions, and workers are unable to access these items on demand or feel that they cannot leave the job without risking their loss.
Withholding of wages is when workers may be obliged to remain with an abusive employer whilst waiting for the wages that are owed to them. Wages are systematically and deliberately withheld as a means to compel the worker to remain, and deny them the opportunity to change employer.
Debt bondage is when is workers are forced into labour to pay off an incurred or sometimes even inherited debt. The debt can arise from wage advances or loans to cover recruitment or transport costs or from daily living or emergency expenses, such as medical costs.
Abusive working and living conditions describe when workers are forced to perform labour under conditions that are degrading (humiliating or dirty) or hazardous (difficult or dangerous without adequate protective gear), and in severe breach of labour law.
Forced labourers may also be subjected to substandard living conditions, made to live in overcrowded and unhealthy conditions without any privacy.
Excessive overtime is when workers are forced to work excessive hours or days beyond the limits prescribed by national law. They can be denied breaks and days off, having to take over the shifts and working hours of colleagues who are absent, or by being on call 24 hours a day, 7 days a week.
How we seek to embed our modern slavery policy in practice
To underpin our policy commitment, we have introduced the following measures:
Raised awareness of modern slavery, through our induction training, and modern slavery policy statement
Provided recruitment specific Stronger Together training for all our employees
Introduced a Responsible Recruitment Policy, which details our commitment to recruiting responsibly and never charging fees for our services
Produced our Compliant Recruitment Principles which all employees involved in the recruitment or deployment of temporary workers are required to sign up to
Introduced specific modern slavery questions into our Approved Supply Process to pre-screen prospective suppliers in relation to the effectiveness of their existing safeguarding controls and practises in relation to preventing modern slavery occurring within their organisation
Introduced a Modern Slavery Steering Group to review the actions we have taken to date and identify and implement further best practise using the Stronger Together resources
Appointed volunteers from within the business to become Modern Slavery Champions to help further raise awareness of modern slavery with workers and peers, promote the different ways workers can report concerns or suspicions of exploitation, and help identify best practice
In addition we:
Have determined that our Labour Suppliers are high risk in terms of modern slavery entering our supply chain, and as such we have introduced additional safeguards in relation to these suppliers
Continue to annually audit our payroll companies to confirm that they are undertaking checks to ensure that temporary workers/contractors are not being subjected to slavery, human trafficking or exploitation
Continue to work to robust placement processes which include compliance checks and identity checks, these processes are reviewed in line with changes in legislation and best practice.
To continue to underpin our policy commitment, we are also in the process of implementing the following measures which will be in place by the end of 2022:
Further assess the risks to our business to determine which parts or our own business and which of our supply chains are most at risk from modern slavery
Review our contractual documentation with suppliers in relation to specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour and the use of child labour in line with this policy
Introduce key performance indicators to monitor the effectiveness of our actions
Responsibility for this Policy
The Manging Director has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
The HR Department will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
Communication and employee awareness training
The HR Department will ensure that all staff receive adequate training on this policy and any supporting processes applicable to their role. Such training forms part of the Company’s induction processes, which is refreshed annually.
In addition, staff will receive training on the broader issues of modern slavery so as to assist them in appreciating the extent of the problem of modern slavery and help identify the individuals/areas of the business that may be at risk from practices of modern slavery.
How to raise a concern
There are a number of ways in which to raise a concern that modern slavery may be occurring in our business or in our supply chain, the procedure/process used will depend on your circumstances and the issue that you are concerned about. You can utilise the following formal procedures to raise a concern:
Grievance Procedure
Whistleblowing Procedure
Complaints Procedure
Close Call System
Alternatively, you may discuss your concerns with your manager/point of contact or the HR department.
Breaches of this Policy
Any breaches of this policy will be taken seriously and dealt with on a case-by-case basis. The breach of this policy by an employee, director or officer of Ganymede may lead to disciplinary action being taken in accordance with the Disciplinary Procedure.
Serious breaches will be regarded as gross misconduct and may lead to immediate dismissal in accordance with our disciplinary procedure. Serious breach by agency workers, contractors, or consultants, may lead to their assignment/contract being terminated. Serious breaches by suppliers may lead to their removal from our Approved Supplier list.
Everybody to whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.
If any part of this policy is unclear, clarification should be sought from the HR Department.