Modern Slavery Statement
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the ‘Act’) and sets out the steps that Alcove Ltd, have taken and are continuing to take to detect and combat modern slavery and human trafficking in all parts of Alcove’s business and supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Alcove has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or supply chain.
An overview of our organisation
Alcove is the market leader in assisted care technology that is providing social care by embracing technology and using connected, smart technologies to keep elderly and vulnerable people safe and better connected whilst allowing them to remain independent in their home. Alcove operates only in the UK.
1. Our supply-chain
Our supply chain consists of third party suppliers and contractors on whom we rely to help execute our projects, through the supply of goods and services. The suppliers vary in size from large corporations to smaller businesses. The supply chain is predominantly UK-based, with some product suppliers based in Europe.
2. Our higher-risk areas
Some of Alcove’s suppliers and contractors are smaller businesses and are not required in law to make formal declarations relating to the Act. Alcove recognises that these suppliers/contractors, along with their suppliers (including those outside the borders of the United Kingdom) present a higher risk to Alcove’s business in relation to the Act. We regularly review these particular types of supplier to assess the risk of modern slavery.
3. Alcove’s policies
We operate a number of internal policies which require that we conduct business in an ethical and transparent manner.
- Anti-slavery policy - which sets out Alcove’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
- Anti-Bribery and Corruption policy – which sets strict limits for the giving or receiving of gifts or hospitality and requires transparency for all employees through no less than quarterly disclosure.
- Whistleblowing policy – which facilitates a third-party confidential line, monitored by SafeCall, in cases where an individual (whether an employee or contractor) discovers information which they believe shows serious malpractice or wrongdoing within the Company (the individual is able to disclose this information without fear of reprisal).
- Recruitment policy – which includes the requirement to conduct eligibility checks for the right to work in the UK for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Code of Conduct - which explains the manner in which all Alcove employees and agents must behave and how we expect our suppliers and contractors to act.
Actions taken to combat modern slavery
1. Obligations on our suppliers
Alcove operates a supplier policy and maintains a preferred supplier list. We conduct pre-qualification due diligence on all new suppliers before allowing them to become a preferred supplier (the ‘PQQ Process’), which is re-completed by suppliers periodically. Alcove’s Modern Slavery & Human Trafficking policy forms part of our contract with all new and existing suppliers and they are required to confirm that no part of their business operations contradicts this policy. We reserve the contractual right to terminate any supplier contract in the event of breach of this requirement.
Given that many of Alcove’s suppliers are long-standing, we have also written to all such suppliers asking them to make the same confirmations to us that we require from new suppliers.
The confirmations we require from all preferred suppliers as part of the PQQ Process are:
- They have taken steps to eradicate modern slavery within their business;
- They hold their own suppliers to account over modern slavery;
- They pay their employees at least the national minimum wage / national living wage (as appropriate); and
- We may terminate the contract at any time should any instances of modern slavery come to light.
2. Contract terms
Our standard supplier terms include bespoke robust anti-modern slavery provisions (including an obligation on our suppliers to obtain similar commitments from their suppliers even where their turnover is below the Act’s £36m threshold).
3. Training and awareness
We conduct periodic training for all of our teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. Refresher training will take place at regular intervals and all new managers with recruitment responsibility receive training in this area.
Periodically, we run awareness programmes to reinforce Alcove’s zero tolerance approach to modern slavery (the “Programme”). This includes talks across the entire business to make all workers aware of the warning signs of modern slavery and how to report these internally so that they can be investigated.
4. Engagement with our supply chain partners
We work with our supply chain to ensure that they implement adequate checks on potentially new sources of labour, thus mitigating an increase in the risk of modern slavery. We oblige all companies tendering to work with Alcove to confirm they will comply with all obligations pursuant to the Act and reserve the right to audit our supply chain to ensure compliance with the Act.
Our performance indicators
Alcove has determined that the effectiveness of the steps being taken to ensure that slavery and/or human trafficking is not taking place within our business or supply chain would be tested against:
- Number of reports received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified; or
- Number of reports received from within our supply chain to indicate that modern slavery practices have been identified.
During 2020/21, there were no reports from employees, the public, law enforcement agencies or our supply chain to indicate that modern slavery practices are taking place. Whilst this of itself is a positive indicator, it is not taken as a cause for complacency and each year the Company strives to further improve the measures it takes to combat the risk of modern slavery.