This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Mason Owen has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Mason Owen has a zero tolerance approach to modern slavery and strives to maintain its commitment to combatting and ending modern slavery in all of its forms. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains. As a responsible and ethical business and employer, no employee of Mason Owen is paid less than the national minimum wage and all our employees over the age of 23 are paid at least the national living wage, in accordance with applicable laws.
The areas which we consider as higher risk are within our Property Management side of the business, whereby we engage with various sub-contractors for the purposes of building security and cleaning. In order to mitigate this risk in addition to the checks outlined below, we ask that our suppliers conduct regular checks about the pay rates and working hours of their employees to ensure that they are compliant with the Working Time Directive 20003/88/EC, and the National Minimum Wage rates.
In order to mitigate the risk in addition to the checks outlined below, we ask our supplier to conduct regular checks about the pay rates and working hours of their employees to ensure that they are compliant with the Working Time Directive 20003/88/EC, and the National Minimum Wage rates. We also regularly meet with the contract lead, to discuss service provisions, and where appropriate any staffing requirements.
Mason Owen operates a supplier policy and maintains a preferred supplier list. We engage directly or via reputable agencies with each of our suppliers and conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery and on site audits which include a review of working conditions.
Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contravenes nor conflicts with this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
Mason Owen requires that each of its staff ensure that they read, understand and comply with this policy.
While we have every reason to believe that there is a very low risk of modern slavery occurring in our business or supply chains, we recognise that prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
Staff are required as part of the private study element of their CPD to familiarise themselves with modern slavery issues so that they are able to identify as part of their day to day work any risk situations which may give rise to cause for concern. Staff are required to report any concerns that they may have in relation to modern slavery to their Line Manager.
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified within our supply change, and during the course of our day to day business and engagement with Clients.
This statement was approved in April 2022 by our Executive Committee, who review and update it annually.