Bramble Effect Group: Anti-Slavery and Human Trafficking Statement for the year ending 31st July 2024
Introduction from the Board
The Bramble Effect Group fully supports the government’s objectives to eradicate modern slavery and human trafficking. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Our companies:
· have not been convicted of any slavery or human tracking offenses anywhere in the world.
· are not currently under investigation, inquiry or enforcement proceedings in relation to any allegation of slavery or human tracking offences anywhere around the world (as far as we know).
Organisation structure and supply chains
Bramble is a small owner managed group of companies: Bramble Hub Limited and Bramble People Limited; and their holding company: Bramble Effect Limited.
Bramble Hub specialises in UK public sector framework contracts for IT and related professional services consultancy. It does this by winning a place on relevant UK public sector frameworks and then involving our network of over 200 subcontractors (“Partners”), almost all SMEs based in the UK (with a few global companies trading in the UK, and a few others based in Europe or USA), to secure and deliver contracts.
Bramble People provides recruitment services to Bramble Hub partners (and a few other UK- based IT companies on occasion). However, this year, neither of these companies have been active.
The rest of this statement focuses on Bramble Hub, although some items apply to the whole group.
Our policies in relation to slavery and human trafficking
Our anti-slavery policy is managed and maintained as part of our Quality and Environmental Management System (QEMS), which is subject to internal audit and external ISO audit and certification. The policy (which applies to the whole group) reflects our commitment to acting ethically and with integrity in all our business relationships, helping to ensure that slavery and human trafficking is not taking place anywhere in our business.
It confirms that, as a matter of policy, we:
1. Do not use forced, bonded or involuntary prison labour.
2. Do not allow our subcontractors to use forced, bonded or involuntary prison labour (which we are contractually enforcing where we can for new contracts).
3. Do not require any of our staff or our subcontractors’ staff to lodge deposits or identify papers with their employer, and that staff are free to leave their employer after reasonable notice
4. Have working due diligence procedures to manage and reduce the risk of slavery or human trafficking in our supply chain performing obligations.
Bramble Effect Limited
5. Do not use, and do not allow our employees or subcontractors to use, physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of our employees or subcontractors. Our employment contracts and associated employment policies and procedures ensure our employees are not allowed to do this.
6. Do not use or allow child or slave labour to be used by our subcontractors.
7. Would report the discovery or suspicion of any slavery or trafficking by us or any of our subcontractors to relevant customers and the Modern Slavery Helpline, if the situation arose. All employees and partners understand that they have a statutory obligation to report knowledge or suspicion of slavery or human trafficking and may do so without fear of discrimination or reprisal.
The policy and associated procedures are reviewed and updated as part of our internal audit process and subject to annual external ISO9001 audit.
Related policies and procedures
As part of our internal audit process, we regularly review and update our other relevant policies and procedures (for the whole group) to ensure they include references to modern slavery and human trafficking where relevant. These include:
· Equal Opportunities and Diversity Policy
· Ethical Purchasing policy
· Partner Risk Management Procedures.
The overall responsibility for the policies lies with the Managing Director.
Due diligence processes
As our turnover is below the current threshold for the Modern Slavery Act 2015, it does not further apply to us and we have no formal legal compliance requirements. However, we have taken the following steps, which are a requirement for companies above the turnover threshold, in any case:
We have:
1. Reviewed our Modern Slavery Risk Assessment for ourselves (our whole group) and our supply chains. No changes were required and it was reissued on 12th June 2024. The conclusions have been included in this Statement and will be reviewed annually.
2. Reviewed the policies, procedures and templates within our ISO 9001 quality management system (QMS) and employee policy/procedure handbook (for the whole group), updated them as necessary (no changes required). This was confirmed at a meeting on 12th June 2024, communicated to all staff on that day, and added to our internal audit schedule to ensure that they form part of the annual quality management review.
3. Made reasonable enquiries (across the group) to ensure our officers (directors), employees and subcontractors have not been convicted of slavery or human trafficking offenses anywhere around the world. This was confirmed at a meeting on 1st August 2024.
4. Reviewed our subcontracts (for the group), ensuring appropriate anti-slavery, -tracking and - trafficking clauses are included and/or flowed down where possible. All our subcontracts flow down responsibilities and commitments from government framework agreements. The majority of those agreements recently issued include Modern Slavery clauses; older agreements will generally do so as they are renewed; this is up to the government (civil servants and public sector officers) to make happen. We will continue to review this.
5. Confirmed that our partners are signing our online form to confirm their ongoing commitment to compliance with the Modern Slavery Act 2015 as part of the partnership registration process and before they can participate on Bramble Hub contracts. This confirms that they conform to the following principles:
· That the Company does not use, nor allow any of its subcontractors to use, forced, bonded, or involuntary prison labour.
· That the Company or any of its employees, directors, officers and any personnel involved in the delivery of the Services under a Contract has not been convicted of any slavery or human trafficking offences anywhere around the world.
· That the Company does not use, nor allow any of its employees, officers or subcontractors to use physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of its employees or subcontractors.
· That the Company does not use, nor allow any of its subcontractors to use, child or slave labour.
This form, signed by an appropriate authority from within the subcontractor gives us a formal record to evidence the ongoing compliance of our supply chain. Partners are required to recommit to these principles annually.
Risk assessment
The assessment of the potential for slavery or human trafficking in our organisation and our supply chains is judged to be VERY LOW, based on our small, owner-managed company, the work we do and the suppliers we work with.
Training on modern slavery and trafficking
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we include our Modern Slavery Policy and Statement in the induction training for new employees. All staff are required to read and confirm their understanding of our current Statement, as part of our annual refreshment training programme.
Key performance indicators to measure effectiveness of steps being taken
We have incorporated the following Key Performance Indicators (KPIs) into our regular internal audit checks:
· All partners’ online commitments to Modern Slavery principles are up to date (CRM checked)
· No reports received of slavery or human trafficking (confirmed by MD)
· All staff aware of the risks of modern slavery and human trafficking (100% confirmed in July 2023 refresher training, evidenced and audited under ISO 9001).
This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015. It was approved by the board on 2nd August 2024.
SIGNED by:
Richard Archer, Managing Director
Date: 2nd August 2024