Modern Slavery Policy
Modern Slavery and Human Trafficking Statement
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty
and dignity for another person's gain. It is a real problem for millions of people around the world,
including many in developed countries, who are being kept and exploited in various forms of slavery.
Every company is at risk of being involved in this crime through its own operations and its supply
At Global Security and Disaster Management Limited (GSDM) we have a zero-tolerance approach to
modern slavery and are fully committed to preventing slavery and human trafficking in our
operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in
our statement. This statement sets out the actions that we have taken to understand all potential
modern slavery risks related to our business, and to implement steps to prevent slavery and human
trafficking during the financial year 2019-20.
Our business and supply chains GSDM is an independent consultancy specialising in resilience solutions in response to man-made and technological risk. Its service and solutions can be adapted to any geographical, risk or sector context worldwide. Primarily we provide consultancy advice through our carefully recruited associate team of consultants; we are also developing digital ‘health check’ tools to assist our clients
in assessing their overall organisational resilience to different types of threat, risk and hazards.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually
beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the
supplier's reputation, respect for the law, compliance with health, safety and environmental
standards, and references.
We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to
the relevant authorities.
In the past year, we conducted a risk assessment of our supply chain by taking into account:
The risk profile of individual countries based on the Global Slavery Index;
The business services rendered by the suppliers;
The presence of vulnerable demographic groups; and
A news analysis and the insights of labour and human rights groups.
This assessment will determine our response and the risk controls that we implement.
GSDM operates the following policies for identifying and preventing slavery and human trafficking in our operations:
Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Purchasing Code - our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier due diligence
GSDM conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
Assessing risks in the provision of particular services;
Auditing the suppliers, and their health and safety standards, labour relations and employee contracts;
Requiring improvements to substandard employment practices; and
Sanctioning suppliers that fail to improve their performance in line with our requirements.
We require all suppliers to attest that:
They don't use any form of forced, compulsory or slave labour;
Their employees work voluntarily and are entitled to leave work;
They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment; They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons;
They don't require employees to surrender their passports or work permits as a condition of employment.
GSDM has raised awareness of modern slavery issues by incorporating this statement and related
policies within its Company handbook which is routinely updated and shared with all employees.
These are aimed at:
Highlighting our commitment in the fight against modern slavery;
Identifying red flags for potential cases of slavery or human trafficking; and
Explaining how employees should report suspicions of modern slavery.
In addition to the awareness programme, where appropriate GSDM undertakes to organise training
for employees and supplier contacts, which covers such issues as:
Various forms of modern slavery in which people can be held and exploited;
The size of the problem and the risk to our organisation;
How employees can identify the signs of slavery and human trafficking, including unrealistically low prices;
How employees should respond if they suspect slavery or human trafficking;
How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation;
What external help is available for the victims of slavery;
What terms and guidance should be provided to suppliers in relation to slavery policies and controls;
What steps GSDM will take if a supplier fails to implement anti-slavery policies or controls. It is already a contractual requirement that all employees fully respect and abide by all of GSDM’s
policies including this one on anti-slavery.
Measuring how we're performing
Where appropriate, GSDM will develop and implement a defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain.
These will include such issues as:
How many employees have completed mandatory training?
How many suppliers have filled out our ethics questionnaire?
How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking?
This statement was agreed and approved on 18 November 2019, and will be reviewed annually.
19 November 2019