This policy forms part of the Chartered Institute of Legal Executives’ (CILEx) internal control and corporate governance arrangements. CILEx means here the Chartered Institute of Legal Executives and its subsidiary companies.
This policy details CILEx’s response to the Modern Slavery Act 2015, documents the roles and responsibilities and outlines the main reporting procedures.
The Group Council of CILEx is committed to ensuring that effective anti-bribery, anti-corruption and anti-slavery and human trafficking procedures operate throughout CILEx. CILEx is committed to carrying on business fairly, openly and honestly with a zero tolerance approach to bribery and corruption.
This policy does not form part of any employee’s contract of employment. CILEx therefore reserves the right to amend this policy and procedure as necessary to meet any changing requirements.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Purpose and scope of Policy
The aim of this policy is to encourage a culture of openness.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
2. Responsibility for the policy 2.1 The Group Council has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Corporate Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
2.3 Line managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
3. Compliance with the policy
3.1 You must ensure that you read, understand and comply with this policy and statement.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
3.4 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Corporate Compliance Manager.
3.5 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Corporate Compliance Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
4. Communication and awareness of this policy
4.1 Awareness training of this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular refresher training will be provided as necessary.
4.2 Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. Breaches of this policy
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Modern Slavery Act 2015 Transparency Statement
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that the CILEx Group is taking to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Although CILEX is not bound by the Act, we are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The CILEx Group has a zero tolerance approach to any form of modern slavery.
The Chartered Institute of Legal Executives (CILEx) is the professional association and governing body for Chartered Legal Executive lawyers, other legal practitioners and paralegals. The CILEx group includes the CILEx Law School and CILEx Regulation, together with two Charitable Trusts- CILEx Benevolent Fund and The CILEx Pro Bono Trust. CILEx represents around 20,000 members. CILEx continually engages in the process of policy and law reform. At the heart of this engagement is public interest, as well as that of the profession.
As it contributes to policy and law reform, CILEx endeavours to ensure relevant regard is given to equality and human rights, and the need to ensure justice is accessible for those who seek it.
Our High Risk Areas
Having assessed our activities we have no areas of operation which would be considered to be of high risk of modern slavery. Operational areas that may be of risk are detailed as follows. This list will be reviewed and updated from time to time:
- Use of staff by subcontractors or suppliers to CILEx, where the suppliers’ processes may not be compliant.
- Employment of sub consultants, suppliers and sub-contractors by CILEx, where their work practices may be non-compliant.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Equal Opportunities Policy: We are fully committed to ensuring that equal opportunities policies are implemented and maintained. All terms and conditions of service apply on a fair and consistent basis to every member of staff.
- Recruitment Policy. We operate a robust recruitment policy, including conducting checks on work eligibility for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing Policy: We aim to encourage openness and will support anyone who raises genuine concerns in good faith under the Whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion.
Our Subcontractors & Suppliers
We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers who share our values.
To this end, the CILEx group will review its supplier policies and create and maintain a preferred subcontractor/supplier list.
Our Modern Slavery policy will form part of our contract with our subcontractors and suppliers and they will be required to confirm that no part of their business operations contradicts this policy.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we intend to roll out awareness training to our Group Executive team and provide regular updates to our staff through our intranet.
Our Performance Indicators
We will know 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 if:
No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.