Modern Slavery Statement

Modern Slavery Statement

Manchester Life Management Ltd has a zero-tolerance approach to modern slavery in our organisation and our supply chains. The prevention, detection, and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.

Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.

Slavery and human trafficking:

No employee shall be subject to slavery or have been the victim of human trafficking. Guidance issued by the UK Government explains what is meant by the terms “slavery” and “human trafficking” as follows:

(a) “Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom.”

(b) “An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job, or may be a child who is influenced to travel by an adult.

In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.”

We are committed to working with our stakeholders and suppliers to mitigate the risk of modern slavery in our operations and supply chain. Our contracting processes are based on a risk assessment, and we regularly review them to ensure effectiveness.

Consistent with our risk-based approach, we may require:

  • Employment and recruitment agencies, as well as other third-party suppliers of workers to our organisation, confirm their compliance with our policy.
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant conducting audits of suppliers to ensure their compliance with our policy.
  • All suppliers must maintain accurate records of the ages and working hours of all employees, who must be at least the legal minimum age as required under the relevant national Law.
  • All suppliers must hold accurate records of the working hours of all employees, and such hours must not exceed the legal maximum. All employees must receive a reasonably acceptable number of breaks, days off, and holidays.
  • All wages must meet or exceed legal minimum levels, and any deductions must be reasonable, agreed upon, and understood by the employees.
  • There must be no discrimination in hiring employees, who should all receive a written employment contract and disciplinary rules in a language they can understand.
  • There must be no physical or verbal abuse of employees.
  • All suppliers must employ a Health and Safety Manager who is authorised to ensure a safe working environment, where all risks of injury from fire, flood, materials, power, equipment, machinery, or hazardous activities have been evaluated and minimised.
  • All working conditions should be clean, hygienic, and comply with all relevant legal standards, ensuring that all employees always have easy access to clean drinking water.

 

If we find that other individuals or organisations working on our behalf have breached this policy, we will take appropriate action. This may include determining whether remediation would best protect affected individuals or whether terminating the relationship is the most appropriate course of action.

Where our staff have concerns about forced labour, human rights, recruitment practices, or exploitation, they are encouraged and expected to report these to our HR department. All reports will be thoroughly investigated.