Modern slavery and human trafficking statement
Modern Slavery Act 2015
Introduction from CMA Management
• Policy Statement
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, agents, contractors and suppliers.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
CMA is committed to improving our practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st September 2018.
CMA strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.
We expect that our suppliers will hold their own suppliers to the same high standards. Commitments Modern Slavery and Human Trafficking Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Modern slavery is a crime and a violation of fundamental human rights. Commitments We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery
We are a provider of full-time claims handling services to insurers, their legal representatives and vehicle information suppliers.
We are known as Claims Management & Adjusting Ltd or CMA or CMA Adjusters; founded in 1994 by the current MD, Philip Swift. We own no limited trading subsidiary, by provide and are sometimes referred to as ‘England Highways’ (englandhighways.co.uk). The principal activity undertaken by the CMA is the resolution of insurance claims, principally vehicle related together with ancillary activities necessary to facilitate this. Additional activities include tracing, social media enquiries and obtaining vehicle data information.
CMA is a body incorporated at Companies House and employs 16 paid staff with an annual of approximately #900,000 at year-end September 2017
• Our policies on slavery and human trafficking
CMA is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy.
Our Modern Slavery and Human Trafficking Policy demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have in place:
Human Resource procedures
• A comprehensive range of policies and practices have been applied including an Equality and Diversity Statement, Dignity at Work, formal grievance and disciplinary policies to protect and ensure that staff rights and responsibilities are upheld.
• Regarding pay, CMA has safeguards to ensure that the hourly rate of staff not fall below the current London Living Wage.
• Engage with our supplier base.
• Identify and monitor potential risk of slavery and human trafficking in our supply chains.
• Incorporate within the tender process to address slavery and human trafficking with potential new suppliers.
Supplier adherence to our values
CMA has a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain (including contractors) comply with our values we have in place a supply chain compliance action list.
• Engage with supplier base to secure a commitment to work with CMA to identify and monitor slavery and human trafficking down the supply chain.
• Engage with potential new suppliers about commitment to our Modern Slavery Policy.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide training to our staff, via Modern Slavery as a regular agenda item to be discussed at management meetings.
Our effectiveness in combating slavery and human trafficking
We have built upon existing monitoring already in place and developed further processes to allow for more effective reporting in the longer term.
• Further steps
Following a review of the effectiveness of steps we have taken to date to ensure that there is no slavery or human trafficking in our organisation and supply chains we intend to take the following further steps to combat slavery and human trafficking.
• Human Resources
Our policies and reporting mechanisms are regularly reviewed to identify areas for further review and issues to be addressed. For example, we are annually audited for ISO purposes to ensure our policies are current, valid and effective.
To check for inconsistencies between policy and practice, CMA undertakes Staff Surveys, which includes questions about the experiences of staff relating to their experience at CMA, instances of bullying/harassment/discrimination and the ability to manage work-life issues as employees.
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships
APPROVED BY SENIOR MANAGEMENT PERSONNEL OF CMA