Modern Slavery & Human Trafficking Statement
This statement is made as part of Coalesce’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Coalesce operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.
Modern slavery can take many forms, including the trafficking of people, forced labour, servitude and slavery. We take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gangmasters. Our processes ensure our employees are alert to the signs of exploitation, in order that we may take the necessary action promptly and effectively should it be identified.
1 Our Business
Coalesce operates in the Consultancy sector. We provide introduction services/supply temporary workers and independent contractors primarily in the Energy and Advanced Engineering industries.
Coalesce Management Consulting Limited is a UK registered Limited Company and operates through subsidiaries in Europe, Asia and the Americas.
1.1 Who we work with
All of the Clients that we work with, and all of the consultants we provide, are known to and identified by our staff. The temporary workers we supply are identified by our staff or our preferred recruiters. Some of the consultants operate through their own limited companies or properly registered businesses. Dependent upon location, some of our consultants are supplied via other businesses, who facilitate providing them to our clients/our clients’ clients.
The hiring companies that we work with are mainly located in the same region as the Services that are being provided. Where this differs, we ensure that all consultants are treated appropriately in line with applicable Employment law and that all taxes/social security are handled legally and compliantly. The consultants we provide and the contractors usually live in the same geographical area as the Services are being performed, but where this differs we make all necessary enquiries to ensure that they are treated properly wherever they are based.
2 Our Policies
Coalesce has a modern slavery policy available here.
In addition, Coalesce has the following policies which incorporate ethical standards for our staff and our suppliers:
• Code of Ethics
• Corporate Responsibility Policy
• Anti-Bribery & Corruption Policy
• Whistle-blowing Policy
2.1 Policy development and review
Coalesce’s policies are established by our Directors, based on advice from HR professionals, industry best practice and legal advice, and in consultation with staff and senior management. We review our policies annually, or as needed to adapt to changes.
3 Our Processes for Managing Risk
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
• We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
Additionally, we have taken the following steps to minimise the possibility of any problems:
• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We require the businesses we work with to address modern slavery concerns in their policies.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
Our staff are encouraged to bring any concerns they have to the attention of management.
4 Our Performance
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of Directors:
• the effectiveness of enforcement against suppliers who breach policies
• the amount of time spent on audits, re-audits, spot checks, and related due diligence
• the level of modern slavery training and awareness amongst our staff
We carefully consider our indicators, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
5 Our Training
All of our staff receive training and support that is appropriate to their role. In particular:
• Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
• Our recruiters, HR personnel, and/or staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking so that they can bring any concerns they have to the attention of management.
As part of this, our staff are encouraged to discuss any concerns that they have.
Training is refreshed annually.
This statement is published in accordance with section 54 of the Act, and relates to the financial year November 2020 to November 2021. It was approved by the board of Directors on 01 March 2021.
Sanjeev Chopra
Finance Director