norwich community money advice connect centre MODERN SLAVERY

Policy statement

1. Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. NCMACC has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. 

2. NCMACC also expects the same high standards from all of its suppliers, contractors and partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards. 

3. Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, NCMACC accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

4. This policy applies to all individuals working for NCMACC or on NCMACC’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy

5. The board of directors has overall responsibility for ensuring that this policy complies with NCMACC’s legal and ethical obligations. The Centre Manage has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in NCMACC’s business or supply chains. 

Compliance

6. The prevention, detection and reporting of modern slavery in any part of NCMACC’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working or volunteering for NCMACC or under NCMACC’s control. You are required to avoid any activity that might lead to a breach of this policy.

7. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify Centre Manager or report it in accordance with NCMACC’s whistleblowing policy. 

8. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of NCMACC’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of NCMACC’s supply chains constitutes any of the various forms of modern slavery, please raise it with the Centre Manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

9. NCMACC 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. NCMACC is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains. 

Training and communication

10. Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases. 

Breach of the policy

11. Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. NCMACC may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

Data Protection

12. In the implementation of this policy, NCMACC may process personal data and/or special category personal data collected in accordance with its GDPR and data protection policy. Data collected from the point at which this policy is invoked will only inform NCMACC for the benefit of implementing this policy. All data is held securely and accessed by, and disclosed to, individuals only for the purposes of this policy. Inappropriate access or disclosure of employee data constitutes a data breach and should be reported in accordance with NCMACC’s GDPR and data protection policy immediately. It may also constitute a disciplinary offence, which will be dealt with under NCMACC’s disciplinary procedure.

Version Control

Modern Slavery Policy
Document Name	Modern Slavery Policy
Document Owner	Version Number	Date Effective	Date for Review	Date of Review and Amendments	Signed
Nik Chapman	1	July 2025	July 2027		Nik Chapman