This is a voluntary statement prepared by Tower Cold Chain. While the obligations of section 54 of the Modern Slavery Act 2015 do not currently apply to Tower Cold Chain, we recognise the importance of its principles and have prepared this statement to demonstrate our commitment to them.
At Tower Cold Chain, we are committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We are an equal-opportunities employer.
At Tower Cold Chain, we are committed to creating and ensuring a non-discriminatory and respectful working environment for our employees. We want our employees to feel confident they can expose wrongdoing without any risk to themselves. Our recruitment and people management processes are designed to ensure all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment. We will not enter into business with any organisation, in the United Kingdom or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and in our supply chains where we can ascertain
Tower Cold Chain maintains the following policies which are accessible to all staff via our electronic systems
- Code of Conduct (Employee Handbook, Section 4)
- Whistleblowing Policy (Employee Handbook, Appendix D)
- Bullying and Harassment policy (Employee Handbook, Section 4)
- Diversity, Inclusion & Ethics Policy (Employee Handbook, Section 4)
Due Diligence Processes for Slavery and Human Trafficking
We have in place policies and systems across our business; we expect our trading partners; and our supply chains to: –
- Identify inappropriate employment practices
- Identify, assess and monitor other potential risk areas
- Mitigate the risk of slavery and human trafficking occurring
- Protect whistle-blowers; and
- Investigate reports of Modern Slavery
Due to the nature of our business, we have assessed ourselves to have a low risk of Modern Slavery in our business.
Embedding the principles
The principles will continue to be embedded by the following activities:
- Provide awareness training to staff on the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking.
- Ensure consideration of the modern slavery risks and prevention are added to our policy review process as an employer and procurer of goods and service.
- Ensure our procurement strategies and contract terms and conditions include references to modern slavery and human trafficking.
- Continue to take action to embed a zero-tolerance policy towards modern slavery.
Supplier Adherence to our Values and Ethics
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we operate in line with principles of responsible employment, including paying employees above the minimum wage.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we provide relevant training to our colleagues. Under our Supplier Code of Conduct we also require our business partners to provide regular and relevant training to their staff and suppliers and providers.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the financial year ending 30th September 2022 and was approved by the CEO of Tower Cold Chain.
This statement will be reviewed and updated annually.