MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
This Modern Slavery Statement has been published in accordance with the Modern Slavery Act 2015. This statement encompasses all group companies of Instant Offices (Holdings) Limited up to our financial year end of July 2019.
We are committed to improving our practices to combat slavery and human trafficking. We are dedicated to understanding the risks and taking appropriate steps to ensure that there is no modern slavery in business and supply chains.
Our Executive Board has overall responsibility for ensuring compliance with this Modern Slavery Statement.
We are a workspace innovation company. We operate globally providing our clients with flexible workspace solutions. Our head office is based in London, United Kingdom. We also have regional hubs in Newcastle, Berlin, New York, Dallas, Sydney, Hong Kong and Singapore. The Instant Group has over 200 employees worldwide and operates in 153 countries.
Our supply chains include firms that provide elements of workspace lifecycle which includes design, fit out and facilities management.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our approach is embedded within our policies and employment practices. Our Head of Supply Chain is responsible for managing the supply chain relationships.
We expect our suppliers to comply with all laws and regulations including anti-slavery and human rights principles in employment. The policies and processes we have in place to help us identify and mitigate risk areas in our supply chains include:
- As part of our supplier procurement policy, suppliers complete a Pre-Qualification Questionnaire which assesses the supplier’s level of compliance with relevant requirements.
- Suppliers are required to comply with our Supplier Code of Conduct which includes anti-slavery and human rights commitments as well as obligations relating to fair labour practices.
- We review the Global Slavery Index (Walk Free Foundation) prior to expansion into new territories and determine action plans where necessary.
If a supplier's practices are found unsatisfactory or non-conformant to our Supplier Code, Instant addresses these issues on a case-by-case basis, seeking advice from subject matter experts and legal counsel if appropriate. We have not experienced any breaches of the Supplier Code related to modern slavery to date. In the event of significant non-conformance, Instant does retain the right to terminate any contractual agreement with immediate effect. Instant is committed to work in the best interests and protection of any confirmed or potential victims of modern slavery.
The following supplier management processes and steps enable us to ensure that our suppliers do not engage with any kind of anti-slavery and human trafficking practices:
- Major Supplier Annual Review. We carry out an annual review which includes checks on supplier performance, policies and compliance with our Supplier Code of Conduct
- Supplier Staff Vetting - We conduct ad hoc checks on our major suppliers for compliance with relevant employment regulations including verifying that suppliers are paying local minimum wage
- Adherence with our Supplier Code of Conduct is mandated through our General Conditions of Purchase and in our Contractual Terms
- Whistleblowing – we have a whistleblowing policy which allows staff to raise concerns confidentially.
Within the business, our operations and legal divisions work together to ensure compliance with our anti-slavery and human trafficking policy. We can measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains by:
- Assessing the risk in our supply chain through the annual audits we carry out on our major suppliers.
- Our requirement on suppliers to provide evidence that they have carried out appropriate staff training sessions.
- Our requirement on suppliers to provide evidence of subcontractor inspections and/or audits where appropriate.
Our goals for 2020 are
Following a review of the effectiveness of the steps we have taken to ensure that here is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:
- Continue collaborating with clients and suppliers to develop awareness (organising Forum Working Group Consultation)
- Implement training and other information resources available to our suppliers (first and second tier) and our employees
- Develop appropriate risk assessment matrix for high risk countries to mitigate risks (country risks /sector risks/transaction risks/Business Partnership risks)
- Include additional checks within our audit process to help identify potential risk areas
- Develop key performance indicators to assess risks to workers
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Instant Group’s slavery and human trafficking statement for the financial year ending 2019.
Signed: Tim Rodber
The Instant Offices (Holdings) Limited
Date: 27 April 2019