Date: February 2023

This statement has been produced in accordance with the Modern Slavery Act 2015 and sets out the actions that Birkdale Sales will take to understand potential modern slavery risks related to its business activities and supply chains. This statement relates to actions and activities during the current financial year.

Our commitments

We are committed to the prevention of modern slavery which includes servitude, forced labour, human trafficking and child slavery. Our Modern Slavery policy is delivered through a range of associated policies and procedures:

• Ethical Code of Conduct Policy
• Recruitment Policy
• Environmental Policy
• Corporate Responsibility Policy
• Work Safe & Whistleblowing Policy

Ultimate responsibility for ensuring prevention of modern slavery and for monitoring compliance to this modern slavery policy is held by John Abernethie, Managing Director.

The responsibility for monitoring of compliance including employee salary, employment rights and supply chain compliance is that of John Abernethie, Managing Director.

Whilst not a large company and thus not covered by the specific requirements of the Modern Slavery Act, we are key contractors to large companies, and thus form an essential part of their due diligence programmes.

The key direct risks of Modern Slavery to Birkdale Sales are:

• No contracts of employment including zero hours contracts.
• Under pay of employees, self-employed contractors and subcontract companies – not paying as a minimum the living wage, and not paying an appropriate market rate for services engaged.
• Excessive working hours – the majority of our direct employees have signed Working Time Opt Out Agreements. It is noted that this can lead in some organisations to excessive working hours, defined as, in line with NHS policy as greater than 56 hours per week, or not providing suitable rest periods between shifts or as a minimum a day off per fortnight.
• Not been entitled to work in the country of employment.
• Poor physical working conditions, including safety conditions.
• Bullying, discrimination and harassment.

Due Diligence

We shall ensure that:

• Individuals have the right to work in the country of employment.
• As a minimum a Living Wage is paid.
• That pay reflects current market values for the sector and role.
• That working hours restrictions are complied with, and excessive working hours discouraged.
• That bullying, discrimination and harassment is not permitted or tolerated in any form.
• That site conditions are safe and provide a working environment conducive to the protection of the environment, human health and quality workmanship.
• In regards to our supply chain our company is a small company and thus our ability to influence the supply chain is limited. We do not sub-contract work. We will however implement due diligence in our supply chain in relation to modern slavery.
• We will issue supplier questionnaires to all our key suppliers to enable us to undertake compliance checks to our requirements and to legal requirements regards modern slavery.
• Our contractual requirements require adherence to the Modern Slavery Act 2015.
• We expect our customers to deliver the same ethical treatment of us as a supplier, particularly in regards to payment terms and conditions, rates of pay and timely payment of applications.

Staff Training

We will provide all management staff training in relation to modern slavery.

Assessing Effectiveness

The delivery of this modern slavery policy shall be monitored and shall form part of annual management performance review.

Corrective Actions

Should an occurrence or potential occurrence of modern slavery be identified, either internally related to employment practice or working conditions, or externally within the supply chain then appropriate corrective action shall be taken in line with the company’s Control of Non-Conformity Procedure. All non-conformity shall be recorded and the required actions implemented in a timely manner.

Any questions?

If you have any questions that have not been covered, please contact our team who will be pleased to help. Contact us