Modern Slavery
Act

The Modern Slavery Act will give law enforcement the tools to fight modern slavery, ensure perpetrators can receive suitably severe punishments for these appalling crimes and enhance support and protection for victims. It received Royal Assent on Thursday 26 March 2015.

The act will:

consolidate and simplify existing offences into a single act
ensure that perpetrators receive suitably severe punishments for modern slavery crimes (including life sentences)
enhance the court’s ability to put restrictions on individuals where it’s necessary to protect people from the harm caused by modern slavery offences
create an independent anti-slavery commissioner to improve and better coordinate the response to modern slavery
introduce a defence for victims of slavery and trafficking
place a duty on the secretary of state to produce statutory guidance on victim identification and victim services
enable the secretary of state to make regulations relating to the identification of and support for victims
make provision for independent child trafficking advocates
introduce a new reparation order to encourage the courts to compensate victims where assets are confiscated from perpetrators
enable law enforcement to stop boats where slaves are suspected of being held or trafficked
require businesses over a certain size to disclose each year what action they have taken to ensure there is no modern slavery in their business or supply chains

Introduction

This statement sets out EyeCare Merry Hill’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2024/2025.

As part of Retail industry and glasses and eye care sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of EyeCare Merry Hill Limited.

An eye care provider located in the well known shopping centre Merry Hill who serves the public in eye tests for all age groups, contact lenses and sale of spectacles.

Countries of operation and supply

The organisation currently operates in the following countries:

United Kingdom

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

Policies: The organisation is always reviewing its policies and the processes by which they were developed.
Risk assessments: The organisation clearly understands its responsibility for human rights and modern slavery risk analysis.
Training: The organisation ensures training is taken place either directly within the company, or with suppliers and others, to better understand and respond to the identified slavery and human trafficking risks.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. Further details of Code of Conduct can be found in the employee hand book.
Suppliers code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
Recruitment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
evaluating the modern slavery and human trafficking risks of each new supplier and may be part of a more general human rights or labour rights assessment;
reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
conducting supplier audits or assessments through the organisation’s own staff/third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
creating an annual risk profile for each supplier;
taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through third party auditor and requiring them to implement action plans [provide examples];
participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular [provide examples such as participation in “Stronger together” or “Ethical trading” initiatives;
using information on suppliers, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationships.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

encouraging staff to have completed training on modern slavery.
In the process of developing a system for supply chain verification; whereby the organisation evaluates potential suppliers before they enter the supply chain; and
constantly reviewing its existing supply chains, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires staff within the organisation to complete training on modern slavery and this may be as a module within the organisation’s wider human rights/ethics/ethical trade training programme.

The organisation’s modern slavery training covers;

our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
how to identify the signs of slavery and human trafficking;
what initial steps should be taken if slavery or human trafficking is suspected;
how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiatives;
what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by including information in the employee handbook.

The employee handbook explains to staff:

the basic principles of the Modern Slavery Act 2015;
how employers can support and prevent slavery and human trafficking;
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
what external help is available, for example through the Modern Slavery Helpline.

Directors approval

This statement has been approved by the organisation’s board of directors who will review and update it annually.

Signature on behalf of Board of Directors:

Date:

20/04/2024