Modern Slavery Act Statement 2018
(Updated) Modern Slavery Act Statement for the year ending 31st March 2018.
Introduction
This is the modern slavery and human trafficking statement for Sense, the National Deafblind and Rubella Association for the financial year ending 31st March 2018. It is the third statement we have made in compliance with section 54(1) of the Modern Slavery Act 2015.
Our business and our structure
Sense is a national disability charity that supports people with complex disabilities to be understood, connected and valued. We work with people living with complex disabilities that can make it a challenge to communicate, access information and take part in life.
We support children and adults to communicate and experience the world, in people’s homes and through our centres and residential provision, holidays, creative and physical activities. We also support families and campaign to change relevant laws and government policies.
Our supply chains and due diligence processes
Sense is committed to ensuring that the organisation and its supply chains are free of slavery and human trafficking, and that the necessary due diligence is undertaken to provide assurance of this.
Our risk analysis for modern slavery and human trafficking affecting our organisation concluded that this is a low risk. The most likely areas through which modern slavery could affect us would be through new goods purchased for our trading arm (i.e. charity shops which raise funds for Sense) and possibly through general procurement for the organization. The Deputy Chief Executive, Kris Murali has overall responsibility for this area of compliance.
We set out below the due diligence processes Sense has put in place to prevent Sense from being involved with modern slavery in any way.
Sense Trading
Our Trading Team secures statements from all suppliers of new goods guaranteeing their compliance with the Act. No supplier is engaged without this compliance statement. During the coming year all longstanding suppliers will be re-reassessed.
Procurement
Sense’s procurement practices incorporate processes to ensure that our major suppliers comply with the requirements of the Modern Slavery Act 2015.
Invitations to tender require suppliers to confirm their compliance with the Act and to provide a formal statement to this effect. If it is considered necessary, they will be asked to provide further assurances.
Depending on the type of goods and services being provided and the depth of the supply chains involved, further due diligence may be undertaken if necessary.
Effectiveness and Assurance
Sense would not tolerate slavery and human trafficking in our supply chains and would terminate our relationship with any suppliers where there was evidence of their failure to comply with the Modern Slavery Act.
Sense is satisfied that, over the year to April 2018, there has been no evidence of any connection with modern slavery or human trafficking, either within the organisation or through any of our suppliers or sub-contractors.
Although it is important to undertake due diligence with our suppliers, we do not consider that it is necessary to set any performance indicators for this area. We have not so far needed to take any action against a supplier.
Our policies in relation to modern slavery and human trafficking;
We are a values–led organisation and we have a number of policies which relate to modern slavery and human trafficking. Our policies on recruitment, whistle-blowing, anti-bribery, equality & diversity and disciplinary and procurement procedures should ensure that modern slavery in any form will not directly impinge on our organisation.
Training our staff about slavery and human trafficking
Staff who work in the areas likely to be affected by modern slavery (Trading and largescale procurement) are trained in our procedures for ensuring that the organisation and its supply chains remain free of slavery and human trafficking.
This statement was approved by the Council of Sense, the National Deafblind and Rubella Association on 19 March 2019, for the year ending March 31st 2018.
Nicholas Keegan, Treasurer
19th March 2019.
(This statement incorporates a previous statement for the year to 31st March 2018 approved by Council in September 2018 and addresses the issues set out in the updated Government guidance).