Anti-slavery & Human Trafficking Policy Statement

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. Frontier Consulting operate a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not take place anywhere in either our own business or in any of our supply chains.

Frontier Consulting are also committed to ensuring transparency within our own business and within our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. Having assessed the potential risks in relation to the Modern Slavery Act 2015, Frontier Consulting have deemed Company Policy not to facilitate Sole Trader status or Zero Hour Contracts within assignments

 

Responsibility for the Policy

Frontier Consulting’s CEO hold overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Directors have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Frontier Consulting invite comments on this policy and suggestions as to ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to a Director of the Company.

 

Compliance with the Policy

It is the responsibility of all employees of Frontier Consulting to ensure that they read, understand and comply with this policy. Such responsibility is outlined during induction upon commencing employment with Frontier Consulting and periodically by Senior Management.  This policy has been approved by the Chief Executive and any breach will be taken seriously and may result in formal action; any individual who considers that the policy has not been followed in respect of personal data about themselves or others is advised to raise the matter with Senior Management.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Individuals are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Senior Management must be notified as soon as possible if it is believed or suspected that a conflict with this policy has occurred or may occur in the future.

All individuals are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If an individual believes or suspects a breach of this policy has occurred or that it may occur, they must notify Senior Management or report it in accordance with our Whistleblowing Policy as soon as possible.

If there is uncertainty regarding whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, this is to be raised with Senior Management.

Frontier Consulting aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any individual believes that they have suffered any such treatment, they should inform Senior Management immediately. If the matter is not remedied, and the individual is an employee, they should raise it formally using Frontier Consulting’s Grievance Procedure.

 

Communication and Awareness of this Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for Frontier Consulting, and regular training will be provided as necessary.

Frontier Consulting’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.

 

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Frontier Consulting may terminate the relationship with other individuals and organisations working on their behalf if they breach this policy.

 

Policy Amendments

Should any amendments, revisions, or updates be made to this policy it is the responsibility of Frontier Consulting’s Senior Management to see that all relevant employees receive notice. Written notice and/or training will be considered.