Modern Slavery

Zone Nation (trading name of Actualised Living Ltd) Statement

Modern Slavery is a violation of an individual’s fundamental human rights and is
against the law. Zone Nation fully support the Modern Slavery Act 2015 (‘the Act’)
which aims to put an end to all types of modern slavery in the UK. Section 54 of the
Act strives to make sure slavery and human trafficking doesn’t take place in business
and supply chains both here in the UK and overseas.

Zone Nation have a zero-tolerance ethos to modern slavery in all its forms. Zone
Nation understand Modern Slavery is a global problem, and we are committed to
ensuring there is no modern slavery or any scope for modern slavery in our supply
chain or in any part of our business operations. All our colleagues, sub-contractors,
agents, and partners are required to carry out all services ethically whilst promoting
good working practices at all levels in accordance with the Act, without reservation.

Definition

Modern slavery is the illegal exploitation of people for personal or commercial gain. It covers a wide range of abuse and exploitation including sexual exploitation,
domestic servitude, forced labour, criminal exploitation and organ harvesting.
(Definitions of each category can be found at the end of this policy along with the
signs of modern slavery)

“Victims of modern slavery can be any age, gender, nationality, and ethnicity. They are tricked or threatened into work and may feel unable to leave or report the crime through fear or intimidation. They may not recognise themselves as a victim.” (The Metropolitan Police.)

Modern Slavery is linked to Human Trafficking, but not all victims of modern slavery
have necessarily been trafficked. In accordance with the Modern Slavery Act 2015, large organisations are required to produce an annual statement. The annual statement is in place to demonstrate compliance with the Act. Zone Nation does not qualify at present, however, Zone Nation will review this yearly for assurance as part of this policy review.

Policy

1. Risk Assessment‍

  • Zone Nation will undertake due diligence checks to identify, assess and mitigate potential risk areas within the organisation and supply chain.
  • Zone Nation will ensure all risks identified have appropriate mitigation and monitoring arrangements in place to ensure our commitment to modern slavery prevention.
  • Zone Nation will regularly review and update our assessments to ensure continued compliance.

2. Suppliers, Agents and Subcontractors‍

  • Zone Nation will ensure due diligence is followed in selection of suppliers,
    agencies and subcontractors to ensure suppliers conduct meet Zone Nation’s
    requirements in relation to this policy.
  • Zone Nation will ensure contracts with suppliers will include their conduct in
    relation to this policy
  • Zone Nation will challenge any abnormally low-cost tenders to investigate the
    risk that they may have engaged a supplier committing modern slavery.
  • Zone Nation will monitor all our supply chain partners, agents and sub-
    contractors for compliance with the Act.
  • Zone Nation will terminate arrangements with any supplier who is found to
    engage in modern slavery within their supply chain and fails when challenged
    to rectify their association.

3. Recruitment and employment

  • Zone Nation will ensure robust safer recruitment and selection processes are
    followed to mitigate the risks of modern slavery entering our workforce.
  • Colleagues will receive information and training to understand what modern
    slavery is and how to report it.

4. Reporting Concerns

  • All Zone Nation colleagues have a responsibility to adhere to this policy and
    relevant Wiki’s, and report concerns relating to Modern Slavery to their line
    manager, or through the Whistle Blowing Policy.
  • Where Zone Nation believe a crime is being committed, HR will contact the
    police in an emergency on 999 or 101 for non- emergency.
  • Where help and advice is required, the Modern Slavery helpline 0800 0121700 can be contacted Review.

‍This policy will be reviewed by Zone Nation with support from the Integrated Management Support Intersourcer at regular intervals but at least annually to ascertain what is working well and what is not working as it might. It will be updated to reflect learning from colleague and individual experiences as well as changes required by regulation and/or legislation. Recommendations for change will be presented to the Board of Directors.

The Law Relating to this Policy

  • Health and Social Care Act 2008 (Regulated Activities) (Amendment)
    Regulations 2014
  • Equality Act 2010
  • Equality Act 2010: Chapter 1 (Protected Characteristics) Chapter 2
    (Prohibited Conduct) and Chapter 3 (Services and Public Functions)
  • Data Protection Act 2018
  • UK GDPR
  • Modern Slavery Act 2015
  • The Care Act 2014

‍Associated Policies

  • Whistleblowing
  • Data Protection