1. POLICY STATEMENT
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Cussins (North East) Limited “Cussins” has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (the “Act”). We expect the same high standards from all of our contractors, suppliers and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.3 This statement is published in accordance with the Act and made on behalf of Cussins and constitutes our slavery and human trafficking statement published in accordance with Section 54 of the Act.
2. ABOUT THIS POLICY
2.1 The purpose of this policy is to:
2.1.1 set out our responsibilities, and of those working for and on our behalf, in observing
and upholding our position on modern slavery and human trafficking; and
2.1.2 provide information to those working for and on our behalf on how to identify and
report concerns regarding modern slavery and human trafficking.
2.2 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
2.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
3. ABOUT OUR BUSINESS
3.1 Cussins is a home builder headquartered in Alnwick, Northumberland. Our business involves buying land, obtaining planning consents, designing, building and selling residential properties within the North East of England.
3.2 The company employs sub-contractors and suppliers visiting our sites on a daily basis in addition to directly employed office, site and sales staff. The majority of our site construction work is conducted through sub-contractors.
3.3 Materials used to build our homes are sourced from UK external suppliers. Our operations mean that we have no direct contact with countries that are generally regarded as being the most likely to have a risk of modern slavery and/or human trafficking.
3.4 We are committed to trading responsibly and ethically and respecting human rights.
4. POLICIES AND DUE DILIGENCE
4.1 As a company we are committed to tackling modern slavery and human trafficking and to work with suppliers and sub-contractors who share this responsibility.
4.2 Our employees are paid at a level not less than The Living Wage. We strive to be an employer of choice and to provide good working conditions and a fair working environment for all our employees.
5. YOUR RESPONSIBILITIES AND HOW TO RAISE A CONCERN
5.1 You must ensure that you read, understand and comply with this policy.
5.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
5.3 You must notify your manager as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
5.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
5.5 If you believe or suspect that a breach of this policy has occurred, or that it may occur, you must notify your manager or report it as soon as possible.
5.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.
5.7 We aim 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. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally with a Cussins Director.
6. BREACHES OF THIS POLICY
6.1 Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.