Modern slavery

Slavery and Human Trafficking Statement

CEPA is a smaller commercial organisation, which does not meet the minimum requirements to have reporting obligations under the Modern Slavery Act 2015. The group’s total revenue is below the threshold of £36m. However, for the sake of openness and transparency, CEPA voluntarily provides the following statement, which sets out the organisation’s approach to tackling modern slavery.

CEPA reports that no entities in its corporate group, have:

• used forced, bonded or involuntary prison labour;
• required staff to lodge deposits or identity papers; and
• sought to prevent staff leaving their employment after reasonable notice.

Furthermore, CEPA warrants and represents that to the best of its knowledge, no entities in its group are under investigation or have been convicted of any offences anywhere around the world in relation to slavery or human trafficking.

We confirm that CEPA has made reasonable enquiries to ensure that its officers, employees and subcontractors have not been convicted of slavery or human trafficking offences anywhere around the world. We have maintained our own policies and procedures to ensure compliance with the Modern Slavery Act throughout the reporting period. Any supplier or subcontractor engaged by us to undertake the supply of goods and or services is contracted to do so in line with our policies:

CEPA implements procedures to ensure that there is no slavery or human trafficking in any part of its supply chain performing obligations under a contract. These procedures are conducted as part of the firm’s onboarding and recruitment process and compliance is kept under ongoing review. The procedures include:

• A robust recruitment policy and process which are compliant with UK employment legislation. The process includes a number of pre-employment checks, for example 'right to work' document checks, referencing and DBS checks are undertaken for relevant posts.
• An employee handbook and mandatory training which defines the responsibilities and standards required for all who work for and on behalf of CEPA.
• Transparent and frequent communication with our supply chain to maintain effective and positive close working relationships.
• A Whistleblowing Policy and access to an external HR advisor, which would support the confidential reporting of knowledge or suspicion of slavery, without fear of reprisal.

CEPA does not use, or allow its employees or Subcontractors to use:

• physical abuse or discipline;
• the threat of physical abuse;
• sexual or other harassment and verbal abuse;
• other forms of intimidation of its employees or Subcontractors; and
• child or slave labour.

Should CEPA discover or suspect any slavery or trafficking by it or its subcontractors, it warrants to report this to the relevant authority.