1.Modern slavery is a serious crime that violates human rights. Victims are forced, threatened, or deceived into situations that strip away their freedom, dignity, and self-worth. We have a zero-tolerance approach towards modern slavery. We are dedicated to conducting our business with ethics and integrity, implementing robust systems to prevent modern slavery in our operations and supply chain.
2.Considering the worldwide reach of CompEx service delivery and the ongoing risk of human trafficking in the energy sector, we recognise that our supply chain poses risks of modern slavery.
3.This policy is issued to comply with section 54(1) of the Modern Slavery Act 2015 and affirms Compex Certification Limited’s commitment to combat human trafficking and modern slavery.
4.The CompEx Senior Management Team is responsible for implementing this policy, in conjunction with the Managing Director, ensuring the adequate allocation of resources, training, and investment to prevent human trafficking and modern slavery from occurring in our supply chain.
Supply Chain Management
5.Our supply chain plays a crucial role in delivering CompEx Certification training and facilitating the provision of our services, encompassing: Primary licensed centres, Satellite Centres, temporary offsite training locations, IT suppliers and third-party marketing providers.
6.Where possible, we endeavour to establish preferred suppliers in our supply chain, fostering enduring relationships.
7.Each agreement we sign must include stipulations around Modern Slavery and the requirement for our partners to have a Modern Slavery policy.
8.To be approved as a Licensed Centre, ATPs must fulfil our Modern Slavery requirements during the application process.
9.In addition, Licensed Centres must adhere to the Modern Slavery requirements stipulated in the Licensed centre agreement. All other supplier agreements we sign must include Modern Slavery policy and due diligence requirements.
Assessing Risk Through Supplier Due Diligence
10.When conducting risk assessments, we prioritise enhanced due diligence for suppliers posing a heightened risk of human trafficking and modern slavery.
11.This process involves enhanced scrutiny during the procurement process and leveraging our available resources and influence to ensure that suppliers meet acceptable standards.
Integrating Human Trafficking and Modern Slavery Risk Reduction into Processes
12.We have conducted a comprehensive review of our onboarding process to identifyopportunities for mitigating the risk of human trafficking and modern slavery within oursupply chain.
13.As a result of this review, we have implemented a series of checkpoints throughout the procurement process. These checkpoints are incorporated from the initial sourcing stage to contract approval, ensuring that risks are consistently assessed, the relevant information is gathered, and supplier selection decisions considering the risk of human trafficking and modern slavery.
Ongoing Monitoring
14.We understand the significance of actively monitoring and auditing our supply chain to ensure ongoing compliance.
15.Our supply chain questionnaire is administered annually via Safety Culture software platform to License Centre applicants, including all existing Licensed Centres and Satellite Centres, IT, and marketing suppliers. This practice allows us to monitor compliance and track improvements within our supply chain.
Training
16. All relevant personnel at CompEx are required to undertake Modern Slavery training during their employment induction and on an annual basis.
Employment Practices
17. All CompEx staff are provided with written employment contracts via its parent company the JTL Group, and their right to work in the United Kingdom is verified before employment starts.
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