As per the (UK) Modern Slavery Act 2015 all bodies corporate and partnerships who (irrespective of where they are incorporated) (1) carry on a business, or part of a business, in the UK supplying goods or services, and (2) have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”.
This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself. The Republic of Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.
In this context, this statement is to be read as applying to PRL Group (Republic of Ireland and Northern Ireland) entities.
Modern slavery is an international crime affecting an estimated 45.8 million individuals around the world. The (UK) Modern Slavery Act 2015 categorises offences of slavery, servitude and forced or compulsory labour and human trafficking. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.
The policy of Green Field Marketing is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws. If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. However, Green Field Marketing will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis. Green Field Marketing is committed to acting professionally and with integrity in all its business dealings and relationships whether in Ireland, UK or abroad.
Green Field Marketing have created a focused Anti-Slavery and Human Trafficking Policy. This policy is reviewed annually.
Reporting knowledge or suspicion of slavery or human trafficking
All employees and directors within the firm have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the relevant Business Unit General manager and to HR, who will decide what further action, if any, is deemed necessary.
Partners and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.
These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.
Green Field Marketing has included appropriate anti-slavery and human trafficking provisions into our Northern Ireland and Republic of Ireland terms of business with clients.
Green Field Marketing has procedures in place pertaining to our employment practices.
Robust recruitment processes in line with Northern Ireland and Republic of Ireland employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16). Market-related pay and reward, which is reviewed annually and linked to industry benchmarks.
We recognise that our firm is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However, Green Field Marketing considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. In addition, our supply chains are primarily confined to Ireland and the UK, countries with a relatively lower risk of modern day slavery and human trafficking.
In this context, we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This is to identify and review supply chains that fall within industries and/or countries that can carry a higher risk of modern day slavery and human trafficking.
We want to help our employees, partners, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.
We are continuing to develop training on the issues of slavery and human trafficking and Green Field Marketing’s anti-Slavery and Human Trafficking Policy, to be delivered to our employees and partners on a periodic basis.
We also plan additional training for employees and partners specifically involved in ensuring compliance with this Policy.
Going forward Green Field Marketing will continue to develop the measures mentioned above in respect of our supply chain. Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2021 and beyond. Green Field Marketing shall take responsibility for this statement and its objectives, and it will be reviewed and updated as appropriate.