Section 1.0 About Us

AliumBlue is a niche partnership of experienced regulated infrastructure sector specialists, providing expert advice to large infrastructure organisations in road, rail, energy, and water. Our Partners are a group of people with a common ethic and complimentary experiences, we work as a collective to offer professional services at a strategic level to support clients in better decision making. We apply and share our knowledge of strategic and regulatory planning, risk and operational management, governance and best practice with our clients. 

Section 2.0 About this document

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. This document sets out our anti-slavery policy in relation to the Modern Slavery Act 2015 and forms a major component of our zero-tolerance approach to the abuse of people in the workplace.  

Section 3.0 Our Statement 

We do not have an annual turnover above £36m, so therefore are not required under this legislation to produce a yearly statement. However, we choose to voluntarily produce a statement.

AliumBlue strictly prohibits the use of forced labour, slavery, and human trafficking in all forms. We are committed to acting ethically and with integrity in all business dealings and relationships.

Legal Framework:

This policy is guided by: 

• Modern Slavery Act 2015
• Employment Law Act 1996 

Section 4.0 Responsibility for the policy

The partnership has overall responsibility for ensuring this policy complies with our ethical and legal obligations, and that all those under our control comply with it.

• The partnership has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and reviewing its effectiveness in ensuring we are countering the risk of modern slavery occurring in our business.

Section 5.0 Our Commitments 

This policy applies to all persons working within the partnership or on our behalf in any capacity, including our Partners, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Our commitments are to: 

5.1 Human Rights

• Act ethically and with integrity in all our business dealings and relationships.
• Maintain a zero-tolerance approach to modern slavery.
• Respect and promote human rights as set out in the legislative frameworks. 
• Provide fair wages and working conditions.

5.2 Employment Practices

• Prohibit the use of child labour, forced labour, and any form of exploitation.
• Ensure that all work is voluntary, and individuals have the freedom to terminate partnership and employment at any time.

5.3 Partnership, Associates and Supplier Standards

• Operate controls to satisfy ourselves, as far as reasonably practicable, that modern slavery is not taking place anywhere in the partnership or in any of our supply chains.
• Conduct due diligence and regular audits to ensure compliance.
• Demand the same high standards from all our suppliers and other business partners. As part of our contracting processes, we will not engage with any organisation that cannot demonstrate that it has policies preventing the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our clients and suppliers will hold their own supply chain to the same high standards.

5.4 Training and Awareness

• Undergo training to help in recognising and addressing risks of modern slavery and human trafficking.
• To help raise awareness about ethical business practices and human rights.

Section 6.0 Implementation and Compliance

6.1 Risk Assessment

• Identify and assess potential risks of slavery and human trafficking in our business operations, associates, and our supply chain.
• Implement risk mitigation strategies.

6.2 Monitoring and Auditing

• Regularly monitor and audit internal operations, associates (where necessary) and supply chains.
• Use third-party audits where necessary to ensure compliance.

6.3 Reporting and Remediation

• Provide a secure and confidential mechanism for reporting concerns about slavery and human trafficking.
• Take appropriate action to investigate and address any reported issues.
• Implement remediation processes for any violations identified.

6.4 Reporting a non-compliance  

We must all ensure that we read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of the partnership or supply chains is the responsibility of us all.

If a case of Modern Slavery is suspected, then the following is advised.

• A suspected victim of modern slavery is not to be confronted directly as this may endanger them.
• If an immediate risk to life, then call 999
• If there is no immediate risk to life, then the Modern Slavery Helpline is to be called 08000 232 700 or it will be reported online. 
• If modern slavery is identified or suspected abroad, then we will engage with local Non-Governmental Organisations, industry bodies, trade unions or other support organisations to attempt to remedy the situation. If warranted, we will contact local government and law enforcement bodies.

Our approach will always consider the safest outcome for the potential victims while also remembering the economic influence and control which the organisation holds over those who may be committing these crimes.

• You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
• If you believe or suspect that a conflict with this policy has occurred or may occur in the future the Partners must be notified at the earliest opportunity.
• Any concerns, issues or suspicion of modern slavery occurring in any part of our business, or supply chains of any supplier must be notified at the earliest opportunity.
• Where appropriate, and with the welfare and safety of people as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any form of modern slavery, raise it with one of the Partners.
• We will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. No one will suffer any detrimental treatment from reporting in good faith their suspicion that modern slavery of whatever form is, or may be, taking place in any part of our business, supply chains. In this regard, detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
• If you believe that you have suffered any such treatment, you should inform one of the Partners at the earliest opportunity.

Section 7.0 Breaches of this policy 

Any person or organisation breaching this policy will face the following action:

• Partners found to be in breach of this policy will be asked to resign their partnership.
• We will, at the earliest opportunity, terminate our relationship with other individuals and organisations working on our behalf if they are found to have breached this policy.
• We will not enter into any commercial or contractual relationships with any organisation that is found to be in breach of this policy or of its own equivalent policy.

This policy is communicated to all our Partners and Associates and is available to other interested parties upon request. This policy and the associated business management system is reviewed annually to ensure that it remains appropriate to our strategic direction and is suitable, adequate and effective. 

Policy authorised by

Signature         Adrian Rees    Wendy Staden    Adrian Kennedy    Vicky Allen    James Elliott    

Name                 Adrian Rees, Wendy Staden, Adrian Kennedy, Vicky Allen, James Elliott

Date                   12th July 2024