In September 2016 the Danbro Group pledged our commitment to ensuring that Modern Slavery of any kind would not be tolerated within our operations and supply chain (our supply chain being anyone that provides a product and/or service to us). By the time of issuing our first Modern Slavery Statement we had already introduced policies and controls to enable reports to be made and action taken.
Our Organisation Structure and Supply Chains
The Danbro Group comprises trading entities that provide accountancy, payroll and financial services to contractors, freelancers and SME’s within the UK. In scope are Danbro Workforce Solutions Ltd, Danbro Employment Umbrella Ltd and Trafalgar Contractor Solutions Ltd. Our supply chain consists of recruitment agencies, other service professionals, general office suppliers, insurers, banks and utilities providers.
Policies in relation to slavery and human trafficking
Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships.
Our Approved Supplier Process will be updated to highlights our expectation that the people and businesses we deal with pay their employees fairly and seeks reassurances that they expect the same of their supply chains.
Due Diligence Processes
- Systems and processes that ensure employee and client information is secure, accurate and auditable
- Identifying those who may be vulnerable and checking on them. Our risk indicators include those:
- Residing in a house with 4 or more other contractor employees;
- Nationality noted as one of the Countries listed as high on the slavery index;
- Individuals whose salary is paid into a bank account that is not in their own name
Reporting on the above will be developed and embedded into our process in the year to March 2022
- Reviewing and updating our agreements and contracts with suppliers ensuring that they are also committed to the abolishment of slavery and trafficking by ensuring compliance in their own business and subsequent supply chain
- Ensuring that all employees are paid at least the National Minimum Wage or National Living Wage and NEVER working with businesses who try to avoid this
- Compliance with Agency Workers Regulations which seeks to ensure no worker is paid less than a comparable directly employed individual doing a similar role
- Updating our Anti-Money Laundering checks in line with new legislation which includes:
- 2017 Money Laundering Regulations
- 2002 Proceed of Crime Act (POCA) as amended by the Criminal Finances Act 2017
- Terrorism Act 2000 as amended by the Anti-Terrorism, Crime and Security Act 2001
- Other anti-terrorism legislation
Risk Assessment and Management
- Reviewing our Risk Register quarterly
- Centrally investigating, recording and alleviating all concerns received about Modern Slavery
- Raising awareness to those in our supply chain of their obligations in this regard
- Performing welfare checks on employees in our high risk categories
- A dedicated compliance team to properly investigate grievances and complaints, as well as working to driving up quality standards
Key performance indicators to measure the effectiveness of steps being taken
|Welfare checks completed||To refresh the criteria for defining vulnerable||80% of those identified as high risk|
|Annual review of policies||To update||Annually|
|Annual refresher training for all employees||To introduce||Annually|
|Quarterly risk register reviews||To include||4/4|
Training on modern slavery and trafficking
- Online Modern Slavery Awareness training for all employees on an annual refresher basis will be introduced in the year to March 2022
- An induction programme for all new starters that includes Modern Slavery training
- Our Anti-Money Laundering training is included in our induction training for new employees and forms part of our mandatory annual refresher training programme
In addition, the Danbro Group continue to be proud of our charitable support. Most significantly we underwrite the administration costs of Operation Orphan, a charity dedicated to supporting and protecting vulnerable children and orphans in the UK and across the world. If you would like to learn more about the excellent work that Operation Orphan does, or wish to get involved, please visit http://www.operation-orphan.org/
Since 2016 we have achieved a greater understanding and awareness of Modern Slavery and Human Trafficking across the Group and strive to do our bit to make the world a safer, more hospitable place for everyone. A world in which people can support themselves and their families, be paid fairly for the work they do without fear of harm or threat of harm.
Our focus this year will be to:
- Increase awareness of Modern Slavery and Human Trafficking through our supply chain by refreshing our message and our Approved Supplier Process.
- Roll out annual refresher training to all internal employees.
- Raise awareness of this issue in a blog post / news update to our contractor employees.
- Continue to support and assist Operation Orphan to protect vulnerable children and orphans both in the UK and abroad
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group slavery and human trafficking statement for the financial year ending 31st March 2021.
DAMIAN BROUGHTON MBE