Portt & Co
Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54 (1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 March 2021.
Portt Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain and its services. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
Organisation structure and supply chains
Portt Ltd trading as Portt & Co is a Limited Liability Company, registered in England & Wales. We provide accounting services to UK Companies. We employ workers in the United Kingdom, Romania and the Philippines.
Our supply chain represents software suppliers, outsourced support services, technical sub-contractors and electronic/office equipment suppliers.
Policies in relation to slavery and human trafficking
We operate a number of policies to ensure that we are conducting business in an ethical and transparent manner. These include the following;
- Supplier Code of Conduct
- Equality Diversity and Inclusion
- Purchasing and Hiring
- Whistleblowing
- Anti-corruption and Bribery
Every new joiner to the firm is given the opportunity to complete an induction, as part of which details of the Code of Conduct and risk management policies are provided. Where a specific need is identified (such as for those involved in procurement), bespoke training is also delivered to enhance the understanding of, and compliance with, the Act and Code of Conduct.
Any breach of the above policies will be taken very seriously, our response to breaches will be proportionate and we will look to engage with employees/suppliers to resolve any issues, however if this process is not satisfactory, further action will be taken. For employees, this can result in disciplinary action, up to and including dismissal without notice. For suppliers, this can result in termination of contracts.
Due diligence
Whilst the risk exposures are low, we are committed to making sure our colleagues stay alert and know what to do should they identify any suspicious activity.
Our control objectives are mapped against risks and designed to classify the control type, outline the purpose of the control, why the control exists and how to perform the control to ensure signs of modern slavery and human trafficking are detected, prevented and reported.
Risk assessment and management
We have evaluated the nature and extent of our exposure to the risk of slavery and human trafficking occurring in our global supply chain through reviewing our own employment practices as well as gaining an understanding our suppliers’ businesses to understand where they source labour.
We consider that we operate in a low-risk environment because;
- We operate a very flat supply chain with high understanding of our suppliers’ businesses
- Our suppliers of labour services are often small companies with highly skilled workers and do not rely on manual labour
- We procure limited products and these are sourced from a few carefully selected suppliers
- The countries in which we operate have ratified International Labour Organization conventions
- The Countries in which we operate have high levels of gender equality
- We control the recruitment of our own workforce
We are fully aware of how to recognise signs of modern slavery and human trafficking through our internal controls which would trigger further probity if identified. Our robust control framework is under continual development in collaboration by the skilled teams delivering our services and those maintaining governance and oversight on our supply chains.
Training on modern slavery and trafficking
All staff are regularly reminded of the signs of Modern Slavery and signposted to Unseen UK.
Those involved in procurement are required to undertake a ‘Modern Slavery in Procurement’ course.
Definition of slavery and servitude
Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom. Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her condition.
Definition of forced or compulsory labour
Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily.
Definition of human trafficking
An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation. The meaning of exploitation is set out on legislation.gov.uk.
Definition of child labour
Child labour is defined by international standards as children below 12 years working in any economic activities, those aged 12-14 engaged in more than light work, and all children engaged in the worst forms of child labour (ILO).
The term ‘child labour’ is often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. Whether or not particular forms of ‘work’ can be called ‘child labour’ depends on the child’s age, the type and hours of work performed, the conditions under which it is performed and the objectives pursued by individual countries.
Children can be particularly vulnerable to exploitation, but child labour will not always constitute modern slavery. It will still be necessary to determine whether, based on the facts of the case, the children in question are being exploited in such a way as to constitute slavery, servitude and forced or compulsory labour or human trafficking. For example, it is possible for children to undertake some ‘light work’ which would not necessarily constitute modern slavery. ‘Light work’ is defined by article 7 of ILO Convention No. 138.
Children do have particular vulnerabilities which should be considered when determining whether modern slavery is taking place. The Modern Slavery Act 2015 specifically recognises that it is not necessary for a child to have been forced, threatened or deceived into their situation for it to be defined as exploitation.