Modern Anti-Slavery and Bribery Policy

Modern Slavery and Human Trafficking Statement

Introduction

This statement sets out The Qubes actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year of 2023. 

As a business, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of The Qube who currently operate in within the United Kingdom, with low-risk activities.

The Qube utilities SIP panel construction to design and manufacture bespoke buildings and units across a variety of sectors within the UK. 

Responsibility

Responsibility for our anti-slavery initiatives which are reviewed annually and owned by our Managing Director include:

• Policies
• Risk Assessments
• Investigations/due diligence
• Training

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy

We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. 

Employee Code of Conduct 

The Qube makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Supplier & Procurement Code of Conduct

We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.

Recruitment Policy

We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency it is using before accepting workers from that agency. 

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review its existing suppliers. Our due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
• evaluating the modern slavery and human trafficking risks of each new supplier.
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
• conducting supplier audits or assessments through [the organisation’s own staff/third party auditor], which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through [third party auditor] and requiring them to implement action plans.
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance Indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

• requiring all staff to have completed training on modern slavery annually
• reviewing its existing supply chains expected to be completed annually whereby we evaluate all existing suppliers.

Training

We require all staff within our organisation to complete training on modern slavery as a module within our wider human rights/ethics/ethical trade training programme.

Our modern slavery training covers:

• our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Awareness-raising Programme

As well as training staff, we have raised awareness of modern slavery issues by circulating a series of emails to staff.

The emails explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

This statement was approved in August 2023 by our Managing Director, who will review and update it annually.