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This statement sets out Proclaim Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 September 2020 to 31 August 2021.


Introduction

Proclaim Group (the organisation) recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.


Organisational structure & supply chains

This statement covers the activities of Proclaim Group:

  • We specialise in devising and implementing rehabilitation programmes to help people deal with the consequences of injury and medical absence from work, returning them back tohealth and back to work.
  • We have a nationwide team of highly experienced medically qualified rehabilitation managers and vocational specialists who provide an integrated medical and vocational rehabilitation service.
  • We provide this service to injured parties who are referred to us from insurance companies, solicitors and employers.
  • To provide our service efficiently and effectively we use various suppliers based throughout the UK.

Countries of operation & supply

The organisation currently operates in the UK only.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is that of the CEO and Leadership Team and is demonstrated in the following areas:

  • Relevant policies
  • Risk assessments
  • Investigations/due diligence
  • Training

Throughout 2020/21 the above will be reviewed and updated to ensure they include Modern Slavery references.


Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

Whistleblowing policy

The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This will include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation.

Standard of business conduct

The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.

Code of conduct for third parties

The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

Recruitment policy

The organisation uses only specified, reputable employment methods and ensures that all relevant employment and security checks are completed for all employees.


Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews will include:

  • Evaluating the modern slavery and human trafficking risks of each new supplier.
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
  • Conducting supplier audits or assessments and ensure they include focus on slavery and human trafficking where general risks are identified.
  • Creating an annual risk profile for each supplier.
  • Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through audit and requiring them to implement action plans.
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

  • Requiring all staff in HR, Supplier Management and Leadership Team to have completed their annual training on modern slavery policy.
  • Continuing to review the system for supplier verification to ensure modern slavery is considered prior to potential suppliers entering the supply chain.
  • Reviewing its existing supply chains to ensure modern slavery is considered whereby the organisation evaluates all existing suppliers.

These KPI’s to be completed by 31 August 2021.


Board approval

This statement has been approved by the organisation’s board of directors, who will review and update it annually.

Approval date: 26 October 2020