Modern Slavery and Human Trafficking Policy

Introduction
Foremost Furniture Ltd acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These make up the supply chain within Foremost Furniture Ltd.

Core Definitions

  • Slavery: exercising powers of ownership over a person, treating them like an object or animal
  • Servitude: the obligation to provide services imposed by coercion, where the person’s living or working status cannot be changed
  • Forced or Compulsory Labour: all work or service extracted from any person under the threat of penalty or coercion, and for which the person has not offered themselves voluntarily
  • Human Trafficking: arranging or facilitating the travel of another person with a view to exploiting them (via force, deception, or coercion)

 Forced Labour and Involuntary Prison Labour

  • Forced Labour Context: victims are frequently trapped through debt bondage, passport confiscation, threats of violence, or threats involving immigration status. This appears in hidden supply chains, agriculture, construction, hospitality, and manufacturing.
  • Prison Labour Rules: under international standards (such as Internation Labour Organisation Conventions), standard work programs inside correctional facilities are permitted if they are voluntary, properly compensated, and akin to normal vocational training. However, involuntary prison labour – where prisoners are compelled to work against their will under the menace of a penalty, or leased out to private commercial enterprises under exploitive, coercive conditions constitutes a severe violation and falls directly under the prohibition of forced or compulsory labour.

The statement sets down Foremost Furniture Ltd.’s commitment to preventing slavery and human trafficking within our business activities and those steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and companies in the supply chain. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns, and management are required to act upon them.

Organisational Structure and Supply Chains
This policy covers all the activities of Foremost Furniture Ltd. It governs all our business dealings and the conduct of all people or organisations with whom we contract directly or who we appoint to act on our company’s behalf.

We expect all who have, or seek to have, a business relationship with Foremost Furniture Ltd and/or any member of our group, to familiarise themselves with our Modern Slavery & Human Trafficking Policy and to act at all times in a manner and way which is consistent with our policy.

To achieve our goals, we will:

  • Issue our suppliers with a copy of our Modern Slavery and Human Trafficking Policy and request they sign to accept compliance with this policy
  • Request a copy of our suppliers Modern Slavery and Human Trafficking Policy
  • Keep our supply chain local where possible, or purchase from reputable European suppliers
  • Ensure that where there may potentially be a risk of slavery and human trafficking, a risk assessment is conducted and acted upon accordingly
  • Conduct audits on suppliers who fall into high-risk categories
  • Identify if any parts of our supply chain or business areas are vulnerable
  • Assess whether activities or countries are considerable risk in relation to modern slavery or human trafficking
  • Consider what type of work is required to make a product or deliver a service (a product made by skilled workers is typically lower risk than those made by unskilled workers)
  • Identify modern slavery risks arising from the geographical location of the supplier

Senior management and directors are responsible for risk assessments in respect of human rights and modern Slavery and human trafficking.

Training
To ensure we have a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the company requires all appropriate employees to complete an induction using the Home Office Modern slavery training: resource page and Modern Slavery awareness booklet. In addition, relevant employees will be encouraged to access the literature and videos available on the Modern slavery training: resource page. Toolbox talks will also be conducted.

Performance Indicators
The company uses the following key performance indicators (KPI’s) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains, including:

  • Requiring all relevant staff to have any necessary training on modern slavery
  • Use of labour monitoring and payroll systems

Policies
The company is committed to ensuring that there is no modern slavery or human trafficking taking place in our business or in our supply chains. This statement affirms it is our intention to act ethically in all our business dealings and relationships.

We always endeavour to conduct our own recruitment activities and/or to only use long-standing reputable employment agencies to source labour. We will conduct appropriate background checks if deemed necessary. Personnel responsible for the recruitment activities are advised to adhere to this policy by ensuring that strict verification of potential employees’ right to work is carried out before any offer of employment is made.

Foremost Furniture Ltd expects the company and all supply chains to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.

Whistleblowing Policy
The company encourages all its workers, customers, and other business partners to report any concerns related to its direct activities or its supply chains. This policy is available to view on our website https://foremost-furniture.co.uk/whistle-blowing-policy/

Code of Conduct
The code of conduct sets down the actions and behavior expected of employees when representing the company.

Corporate Social Responsibility (CSR) Policy
The company’s CSR policy summarises how we manage our environmental impacts and how we collaborate responsibly with suppliers and local communities.  This policy is available to view on our website: https://foremost-furniture.co.uk/corporate-social-responsibility-policy/

Senior management and directors are responsible for creating and reviewing policies.

Due Diligence Processes for Slavery and Human Trafficking
The company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The company’s due diligence process includes:

  • Building long-standing relationships with suppliers and making clear our expectations of business partners
  • Keeping our supply chain local where possible; or purchasing from reputable European suppliers
  • Evaluating the modern slavery and human trafficking risks of each new supplier
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Senior management and directors are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

The policy on modern slavery will be communicated to all suppliers, contractors, and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter. Our policies are available to view on our website: https://foremost-furniture.co.uk/policies/

The Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated when it is necessary. The Directors of the company endorse this policy statement and are fully committed to its full and effective implementation.