1.1 To reduce the risk of modern slavery occurring within our business by informing all persons working for, or on behalf of our companies (Thrive Architects Limited, Thrive Architects (South West) Limited & Thrive Architects (Thames Valley) Limited) including employees, Directors, agency workers, contractors, consultants and any third party representatives.
2.1 Modern slavery is a crime and a gross 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.
2.2 Thrive Architects Limited, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited has a zero-tolerance approach to modern slavery and we are committed 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.
2.3 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, suppliers or any other people or bodies associated with the business.
3.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal obligations, and that all those under our control comply with it.
3.2 The Anti-Slavery Policy Compliance Team (the ‘Compliance Team’) which comprises of the Group Technical Director and Group HR Director will work to ensure that this policy is maintained across all operational areas of the Group in accordance with evolving regulatory requirements and to ensure that any breaches or concerns are addressed.
3.3 The Group HR Director has primary and day-to-day responsibility in relation to our supply chain for implementing this policy and monitoring its use and effectiveness, dealing with any queries about it, auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
3.4 The Group HR Director has primary and day-to-day responsibility in relation to those directly employed by us for implementing this policy and monitoring its use and effectiveness, dealing with any queries about it, auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
4.1 All persons working for Thrive Architects Limited, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited must ensure that they read, understand and comply with this policy.
4.2 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. All persons working for Thrive Architects Ltd, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.3 All persons working for Thrive Architects Limited, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited 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 at the earliest possible stage, by reporting it in accordance with our Whistleblowing Procedure.
5.1 The HR Director, oversees the carrying out of the official Home Office Right to Work in the UK checks for all new employees. This is in accordance with the Immigration, Asylum and Nationality Act 2006.
5.2 As part of the offer pack, the potential employee is sent a checklist showing details on how they can provide the evidence of their right to work in the UK so the check can be carried out. The check needs to be completed either before or on their first day of work with the company.
5.3 Once the check has been completed and clearance has been granted, the documents which have been copied are signed and dated by the HR official and saved in the employee secure folder. If the check was unsuccessful, then the potential employee is made aware and is unable to commence employment until this has been discussed with the Home Office.
5.5 Any current employees who visa/work permit is due to expire, they need to provide evidence that their application is in process or has been extended or successful in obtaining permanent residency and right to work. A copy of this will be taken and saved as in step 5.3.
6.1 This policy is communicated to all Thrive Architects Limited, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited employees through our induction process and the latest version of the policy is uploaded onto the internal SharePoint, which all employees have access to.
6.2 Thrive Architects Ltd, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited employees are required to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce our approach as appropriate thereafter.
7.1 In order to give effect to our zero-tolerance approach, we have systems in place to ensure that all employees and those in our supply chain implement our policy. These will be kept under review by the Compliance Team.
8.1 Any breach of this policy will generally be treated as gross misconduct and may result in dismissal without notice. Each case will be dealt with on a case-by-case basis.
8.2 We may terminate our relationship with individuals or organisations working on our behalf if they do not comply with this policy.
8.3 We expect co-operation to the fullest extent possible in any investigation into suspected breaches of this policy.