Modern Slavery Policy

Modern Slavery and Human Trafficking Policy

Introduction

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour.

ENI has a zero tolerance to any form of Modern Slavery and are committed to acting ethically and with integrity and transparency with all business dealings and to putting effective systems and controls in place to safeguard any form of modern slavery taking place within our business or our supply chain.

We are committed to ensuring that there is no Modern Slavery or Human Trafficking in any part of our business or our supply chain.

Our policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure human trafficking and slavery is not taking place in any of our supply chain”

This policy outlines the governance of the Modern Slavery Act 2015 and reiterates the responsibilities to ensure the business is compliant with the legislation.

ENI are committed to act ethically, with integrity and transparency in all business areas, and will ensure transparency within the Company and external suppliers and fully support the governments objective to eradicate modern slavery and human trafficking.

The Modern Slavery Act 2015 covers four activities:

Slavery: Exercising powers of ownership over a person

Servitude: The obligation to provide services is imposed by the use of coercion

Forces or compulsory labour: Work or service are extracted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily

Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation

Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part.

Identifying slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.

However, the following key signs could indicate that someone may be a victim of the above 4 listed activities (this list is not exhaustive):

  • The person is not in possession of their own passport, identification or travel documents
  • The person is acting as though they are being instructed or coached by someone else
  • They allow others to speak for them when spoken to directly
  • They are dropped off and collected from work
  • The person is withdrawn, or they appear frightened
  • The person does not seem to be able to contact friends or family freely
  • The person has limited social interaction or contact with people outside their immediate environment

We all have responsibility to ensure everyone who works with ENI is safeguarded, treated fairly and with Dignity.

ENI Recruitment policy.

ENI operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all candidates and direct employees.

ENI allow Clients to audit our processes and provide them with the assurances that pre-employment clearance has been obtained for all our contractors. candidates and employees to safeguard them against human trafficking or individuals being forced to work against their will.

Equality, Diversity, Inclusion and Belonging

We have a range of controls in place to protect employees and contractors and candidates from poor treatment and/or exploitation, which comply with all respective laws and regulations.

These include provision of fair pay rates, fair terms and conditions of employment and access to training and development opportunities as required.

Whistleblowing

ENI operate a whistleblowing policy so that all employees, candidates, and contractors know that they can raise concern about how fellow employees or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals

Managers Responsibilities and ENI

All employees have responsibilities under this policy. Whatever role or level of seniority, they are required to:

  • Keep their eyes and ears open—if suspecting someone (a fellow employee, candidate, a contractor, or someone in the supply chain) is being controlled or forced by someone else to work or provide services, they are required to follow the Company reporting procedure, or call 999.
  • All employees need to follow the Company reporting procedure if a fellow employee , candidate or contractor informs them, or may indicate to them that they are, or someone they know is being exploited or ill-treated.
  • All employees have the responsibility to inform the Company if they think there is more the Company can do to prevent people from being exploited.

Procurement

The Company’s approach to procurement includes ensuring that a Preferred Supplier List (PSL) is used with all suppliers.

ENI safeguard the business by auditing all new suppliers at the beginning of a contract and thereafter on an annual basis.

Where it is verified that a contractor has breached the Modern Slavery Act 2015 then the contractor will automatically be excluded from business interaction, and an investigation will be immediately carried out.

Should ENI have concern, this will be reported the relevant authorities.

Training

ENI will provide training to all Recruitment Consultants and Delivery employees responsible for recruitment on behalf of the Client and all employees responsible for recruitment on behalf of the business.

ENI are continually looking at ways to increase awareness to ensure all employees understand the risks involved with Modern Slavery and Human Trafficking in our supply chain and in our business.