This Policy Statement is made in accordance with the requirements of the Modern Slavery Act 2015 and constitutes Code 9 Security’s position in respect of modern slavery and human trafficking. 

Policy Statement

Code 9 Security is committed to combating modern slavery and human trafficking and takes responsibility for ensuring its working practices are compliant with the Modern Slavery Act 2015 and best ethical practices. 

This Policy Statement reflects our commitment to acting ethically and with integrity in everything we do, implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our Company, supply chain or partner organisations. 

Due Diligence

We undertake regular audits of our business and supply chain, at least once per annum, to assess areas of risk and potential exposure.

The likelihood and severity of risk within our own business have been found to be low. 

As part of the Company’s due diligence process, we continually monitor and adopt effective systems to ensure Code 9 Security does not support, directly or indirectly, or have any dealings or relationships with a business or individual involved in slavery or human trafficking. 

Supply Chains

We operate a zero-tolerance policy to slavery and human trafficking and take proactive steps to police our supply chains to identify, eliminate and control risk.

Our procurement policies examine the awareness and compliance of our suppliers, and their suppliers as part of our due diligence undertakings. Further, we require our suppliers to adhere to our ethos, share common goals in eliminating modern slavery and human trafficking and more generally demonstrate compliance with the provisions of the Modern Slavery Act 2015. 

In sourcing goods and services, our colleagues take positive steps to ensure we only engage with trusted supply chains and fully assess the risk with new supply chains. 

Moreover, the provisions of this policy are entrenched at the heart of our purchase contracts and each supplier is expressly required to confirm their acceptance and give an undertaking to uphold the same.

Recruitment

Our recruitment and human resources policies, procedures and practices ensure compliance with the Modern Slavery Act 2015, employment law and general best practice.  

All of our personnel are subject to thorough screening and vetting per the requirements of British Standard 7858. Through these procedures, we have detailed checks to ensure candidates have the right to work in the United Kingdom, as well as establishing verifiable checks against address history and employment history for a minimum of 5 years with any gaps being both explained and evidenced.

As a matter of best practice, we routinely review our recruitment policies, procedures and practices adopting changes in employment law, changes brought by the withdrawal from the European Union in concert with best practice. 

Awareness

As a matter of best practice, all of our colleagues are required to have a general awareness of modern slavery and human trafficking and the signs, symptoms and indicators of the same – and have a positive duty, within the scope of our Conduct Regulations to report any concerns or non-compliance.

Additionally, colleagues with supervisory, management and executive roles are required to take positive steps to ensure compliance with our modern slavery and human trafficking policy, be able to recognise signs, symptoms and indicators and effectively report and act on suspicions of the same.

Reporting

If a colleague has a concern regarding a risk, howsoever slight, or an actual breach of our Policy or the legislation, they have a positive moral and contractual duty by virtue of the Conduct Regulations to report this to the Board of Directors – and in cases where a person is in the immediate risk of harm, to the police. 

Reporting can be made through all of the available established reporting mechanisms and through the Whistleblowing Procedure. 

Endorsement 

This Policy was re-approved by the Board of Directors on 06 April 2023 and shall be reviewed again in April 2024.