Modern Slavery Act 2015
1. Introduction from FourSynergy Group Limited
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. It continues to be a priority for FourSynergy Group Limited to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain, including a range of transparent policies and strategies aimed at improving our current practices and ensuring consistency across our subsidiaries.
2. Organisational Structure and Business Model
We are a leading nationwide provider of Specialised Supported Housing (SSH), and seek to deliver high-quality homes to vulnerable groups such as those with disabilities, mental health conditions, elderly etc. We understand the rising number within such groups and the limited housing supply in the current market, and have therefore sought to introduce a new, functional model comprised of four specialist areas. These four specialist business areas – Care, Housing, Development, and Investment – allow us to combine expertise in order to drive sustainable and impactful development within the SSH sector. The contents of this Statement shall have the same meaning and applicability across all subsidiary companies forming under FourSynergy Group Limited.
3. Our Policy on Slavery and Human Trafficking
We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to enforcing effective systems and controls to ensure slavery and human trafficking is not occurring within our supply chains. 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 partner.
4. Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk in relation to modern slavery, we have implemented the below:
a) We have introduced a comprehensive range of policies including Equality and Diversity policies, formal Grievance and Disciplinary processes and Special Leave Procedures to ensure that the fundamental rights and responsibilities of individuals are protected.
b) We are also in the process of implementing a company-wide scheme named ‘ESG’ (Environmental, Social and Governance Concept) which seeks to introduce several valuable mechanisms of business and corporate responsibility. This includes a Procurement Working Group, which will enable us to engage with our supplier base and monitor any potential risks of slavery/human trafficking while tendering new procedures to ensure consistency across our supply chains.
5. Supplier Adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our ethical standards, we are introducing a supply chain programme under the ESG scheme. The intended purpose of this area of the scheme is to assess current standards within our supply chains and incorporate bodies such as the Procurement Working Group, who will approve and formulate functional strategies to ensure compliance with our modern slavery commitments. In order to maintain the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we have carved out specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We also expect our suppliers to hold their own suppliers to the same very high standards we adopt and aim for our future policies to foster greater accountability in this respect.
6. Raising Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff and have incorporated this into our general induction processes across all subsidiaries and external parties. In this way, our zero-tolerance approach to modern slavery is communicated at the outset of all business relationships and is reinforced in the appropriate manner thereafter.
In addition, as part of our initiative to identify and mitigate risk we encourage all employees to raise concerns regarding any issue or suspicion of modern slavery in any parts of our business or supply chains. Our businesses aim to encourage complete transparency and we will support any individual who raises genuine concerns in good faith by virtue of our policy.
7. Further Steps
Following a review of the effectiveness of steps we have taken to date to ensure that there is no slavery or human trafficking in our organisation and supply chains we intend to take the following measures to combat slavery and human trafficking, as part of our ESG scheme:
a) By dividing keys areas of the business model in multiple facets, we can address core concerns such as Staff Wellbeing, Equal pay, and the Health and Safety of employees, from a broader and specialised perspective. For instance, in terms of workplace safety, we are considering a host of new operations including revised Health and Safety Risk Assessments and Employee Assistance Programmes.
b) We are intending to establish several committees, which include the Risk Committee and Audit Committees – by enforcing such governance mechanisms, we are striving to advance our monitoring systems and aim for a comparatively stronger compliance process that aligns with our modern slavery principles.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2022. It was approved by the board on 04/08/2022.