Modern Slavery Policy

Modern Slavery Act Transparency Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced or 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. These are offences under Sections 1 and 2 of the Modern Slavery Act 2015.

Concert adopts a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We take responsibility for preventing the use of forced, compulsory or trafficked labour, anyone held in slavery or servitude, whether adults or children, within our own organisation, those who work on our behalf and under our direction in the conduct of their daily business and that of our business partners and our supply chain. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Concert adopts fair recruitment practices and accept that the cost of recruitment is a business cost and should be borne by the employer and never by the worker. We verify the identity of each employee and their right to work in the UK. All our employees are provided with a clear contract of employment, which complies with local legislation, and all employees must be treated in a fair and equal manner, with dignity and respect. No young person under the age of 18 may be employed to work at night or for any hazardous work and their employment must not harm their education, health, physical, mental, or social development.

Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependents, religious or philosophical belief should be prohibited.

We will never knowingly engage with suppliers or subcontractors who do not commit to meeting applicable legal standards relating to human rights and labour standards. We expect our supply chain to respect the human rights of their employees and contractors and treat them fairly, in accordance with all applicable laws. Supply chain companies should ensure the work relationship between their workers and the supplier is freely chosen and free from threats and that all workers are free to leave their employment or work after giving reasonable notice in compliance with all applicable laws. Supply chain companies must not use any forced or child labour.

The owners of Concert have overall responsibility for ensuring the operation of our business complies with our legal and ethical obligations, and that all those under our control adhere to our standards. The HR Team has primary responsibility for auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Any person concerned about a breach of fundamental human rights should raise their concerns with their line manager or the HR Team. Some of our clients may have their own anti-slavery policies and all Concert employees should familiarise themselves with those to also abide by their requirements.

Modern Slavery Definitions

Modern Slavery is a term used to encapsulate both offences in the Modern Slavery Act: slavery, servitude and forced or compulsory labour; and human trafficking. The offences are set out in section 1 and section 2 of the Act, which can be found at:

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/herself 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 here: ukpga/2015/30/section/3/enacted.

Recent figures from the UK National Crime Agency (NCA), show that the most prominent exploitation type recorded for potential victims first exploited as a child (where this is known), was labour trafficking.

Behaviour Constituting Modern Slavery

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness seep into instances of human trafficking, slavery or forced labour in a work environment. However, businesses have a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment (include wage and work hour), health and safety and human rights laws and international standards are adhered to, including freedom of movement and communications.

There will be cases of exploitation that, whilst being poor labour conditions, nevertheless do not meet the threshold for modern slavery – for example, someone may choose to work for less than the national minimum wage, or in undesirable or unsafe conditions, perhaps for long work hours, without being forced or deceived. Such practices may not amount to modern slavery if the employee can leave freely and easily without threat to themselves or their family. Organisations do still nevertheless have a legal duty to drive out poor labour practices in their business, and a moral duty to influence and incentivise continuous improvements in supply chains.

Slavery and human trafficking offences

Nationality, Immigration and Asylum Act 2002
Sexual Offences Act 2003
Criminal Justice (Scotland) Act 2003
Asylum and Immigration (Treatment of Claimants, etc) Act 2004
Coroners and Justice Act 2009
Criminal Justice and Licensing (Scotland) Act 2010
Modern Slavery Act 2015
Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland)