Pursuant to the Modern Slavery Act 2015, Grayce has a zero-tolerance approach and active commitment to preventing acts of modern slavery and human trafficking from occurring either directly through our business or through our supply chain. Grayce is committed to imposing the same high standards on suppliers at all times.
Whilst Grayce is ultimately responsible for ensuring there is no risk to modern slavery and human trafficking, we expect our employees to be accountable for compliance with our related policies.
Employment must be a voluntary choice and any attempt to force or deprive an individual of liberty is not only strictly prohibited, but a matter than should be prevented at all costs. To uphold our commitment, we refuse to work with any suppliers who may specify money as a condition of employment. Suppliers must allow employees to freely serve notice and leave employment at their will, with a reasonable notice period.
This statement is fully supported by all members of Grayce’s Executive Board.
Grayce has received no prior reports of modern slavery or human trafficking.
Grayce is a management consultancy, currently UK-based, with expansion plans to undertake consultancy work on behalf of clients based in the United States of America. Grayce operates across various sectors including, but not limited to:
We do not expect that the sectors in which Grayce operates are at high or significant risk of forced labour, slavery and/ or human trafficking.
As of November 2023, Grayce employs a total of 588 people currently based across the UK.
Further information on Grayce’s business can be found: Grayce Webpage.
Grayce has various supply chains to ensure the effectiveness and efficiency in business operation. Within all supply chains, Grayce proactively strives to ensure suppliers adopt a consistent approach to modern slavery and trafficking and are low risk.
Grayce’s supply chain includes:
This is not an exhaustive list.
In general, Grayce’s supplier relationships are long-term and will continue as long as they add value to Grayce’s business operations and compliance. On occasion, some supplier relationships will be short-term and possibly one-off, these could be one-off catering & hospitality agencies, stationery or office equipment suppliers or some recruitment agencies.
All supplier relationships are critical to the business operation at Grayce and at the time of publishing this policy, all suppliers were based in the UK or US.
Grayce’s policies are managed centrally by the Human Resources team. They are developed by qualified business professionals who are experienced in their areas of expertise. Some policies are reviewed by external contractors such as Grayce’s appointed qualified lawyers.
As part of our ongoing commitment to combating modern slavery and human trafficking, Grayce operates with the below referenced policies in place:
All policies are available to all employees at any time. They can be accessed via our HR system, People+, independently and without prior permission. Grayce employees are obliged to comply with all policies.
Grayce reviews policies on a regular basis to ensure they are updated in line with legislative and best practice changes.
Suppliers are proactively made aware of our policies and adhere to the same high standards of operation, either through adopting Grayce’s policy requirements or by implementing their own policies which cover similar requirements.
At Grayce we promote human rights. We have stringent due diligence procedures in place to enable us to monitor and reduce risk of slavery and human trafficking occurring within our supply chains. We aim to establish and assess areas of potential risk both within our business and supply chains.
Our due diligence procedures are outlined below.
Each employee of Grayce has a written contract of employment which includes a guarantee of pay and benefits, along with a reasonable period of notice which enables them to resign and leave freely.
All employees have free, unlimited and anonymous access to mental health services. In addition, Grayce offers access to appointed and trained mental health first aiders at all times internally within Grayce.
We have a clear Whistleblowing Policy which sets out the whistleblowing procedure. Whistleblowers are guaranteed protection from unfair or negative treatment as a result of taking action under this policy.
Contractors within Grayce’s supply chain are provided with appropriate terms within contractual documents, obliging suppliers and contractors to comply with the Modern Slavery Act and reserve the right for Grayce to audit suppliers and contractors where we consider it appropriate. Grayce is not involved with any client transactions.
We have key stakeholders who are allocated to manage client relationships and supplier relationships. The business relationships are reviewed on an ongoing basis and commitments are clearly stated within the contracts. The key stakeholders are responsible for monitoring and enforcing the policy to clients, and are trained to raise any concerns to HR.
We have a number of ad-hoc suppliers, such as stationery, florists and catering, in which transactions are handled and will be reviewed on a case-by-case basis.
We do not consult with any external third parties to carry out anti-slavery checks on specific suppliers, or in relation to specific supply chains as the risk is low.
Grayce does not deem itself to operate in countries that are specifically vulnerable to slavery and human trafficking, however many of our clients operate in countries that may be deemed to be higher risk.
Our potential risks include operating in varying sectors and countries where protection against human rights are limited.
Our suppliers are expected to have suitable modern slavery and human trafficking policies and processes in place within their own businesses and to cascade those policies to their own suppliers. Should suppliers fail to comply with our policies, we would immediately seek to terminate our relationship with that supplier.
Suppliers are required to report on any identified risks or concerns using the procedures outlined within their respective policies. If a process for reporting risks or concerns is not clearly outlined within supplier policies, Grayce expects that suppliers will follow Grayce’s reporting procedure.
Breaches or risks identified under this policy may result in disciplinary action under Grayce’s Disciplinary Policy.
Grayce has implemented KPIs to measure the success of ensuring slavery and human trafficking is not taking place in any area of our business or supply chains. These are as follows:
We produce reports which allows Grayce to see which employees have successfully passed the modern slavery training. If employees have not completed this training, they will be given a strict deadline to complete the training. These reports are run on an annual basis to ensure that all employees are keeping up to date with compliance training. These reports are used for Grayce employees only.
The majority of employees at Grayce work on our client’s sites and therefore are able to monitor working conditions. Those employees also keep in close contact with their managers within HQ in which they can raise any concerns.
If a supplier fails to meet desired standards in relation to modern slavery KPIs, this could result in a termination of the contract.
Upon commencement of Grayce employment, all employees are signposted to our relevant and related policies to ensure they are aware of the risks of modern slavery and human trafficking both within our business and our supply chains.
Compliance training is conducted via an external provider using an online platform known as Atlas (previously iHasco). All employees are required to complete compliance training as part of initial 90- day goals and must recomplete training assessments on an annual basis. The training provided is aligned to Grayce’s stance on slavery and human trafficking and completion is monitored on an ongoing basis. Training is available in different languages if necessary.
Employees are made aware of how to report and escalate issues from the onboarding stages of employment.
This statement and commitment to preventing modern slavery and human trafficking is supported entirely by Grayce’s Executive Board. We are committed to continuously reviewing policies, procedures, practices internally and that of our suppliers. We endeavour to invest in training that is relevant to ensuring we are our entire workforce are aware of steps required to prevent modern slavery and trafficking.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Grayce’s slavery and human trafficking statement for the financial year commencing April 2023 and ending March 2024. This statement was approved by Grayce’s board of governors on 22nd November 2023.
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