Modern Slavery and Human Trafficking Statement

Financial Year December 2017 – November 2018

Introduction

Mannion Daniels Limited is committed to complying with the United Kingdom’s Modern Slavery Act 2015. We take a zero-tolerance approach to modern slavery and enforce effective systems and controls to ensure modern slavery and human trafficking is not taking place in our business or our supply chain. Mannion Daniels Limited is required to publish a Slavery and Human Trafficking statement for each financial year. This statement is made pursuant to section 54(1) of the United Kingdom’s Modern Slavery Act 2015 and is Mannion Daniels Limited’s updated modern slavery and human trafficking statement for Financial Year December 2017 – November 2018.

Our organisational structure, business and supply chains

Mannion Daniels Limited is a public limited company registered in England, offering consultancy and fund management services. Our mission is to work for a healthy, equitable, inclusive, safe and sustainable world. We focus on fragile and conflict-affected states, to ensure that our work reaches the world’s poorest and most vulnerable people. Mannion Daniels Limited (MannionDaniels) is part of the MannionDaniels group of companies with offices in Kenya and Nigeria. We have over 18 years of experience in the development sector and have delivered services in more than 50 countries across the globe.

MannionDaniels’ supply chains consist of partners and self-employed consultants located in the UK and overseas who work with us to provide services and operational support suppliers providing goods and services to the business at corporate and project level. We are cognisant that our supply chains operate in high-risk environments including countries with endemic poverty, fragile governance structures and lack of awareness of human trafficking and modern slavery. These countries also have weak systems to monitor and respond to human rights abuses and incidences of modern slavery. In our supply chain, we strive to engage only with business partners, consultants, suppliers and associates who demonstrate a serious commitment to health and safety and operate in compliance with human rights laws. We aim to ensure that modern slavery and human trafficking is not taking place in our operations and in the supply chains that provide their goods and services through robust and regularly updated policies, guidelines, training and mechanisms to detect and prevent modern slavery and human trafficking.

Our polices and approach in relation to modern slavery and human trafficking

MannionDaniels upholds the highest standards of conduct in the delivery of our services and adheres to well defined ethical values and practices. Our business code of ethics outlines our ethical values and practices; these are accountability, integrity, inclusion, innovation, high performance, transparency and environmental responsibility. The key policies and procedures that relate to mitigating risks of modern slavery and human trafficking in our business and supply chain include:

  • Business Code of Ethics
  • Corporate Social Responsibility Policy
  • Due Diligence Policy
  • Equality and Diversity Policy
  • Modern Slavery and Human Trafficking Policy
  • Procurement Policy
  • Recruitment and New Starters Policy
  • Risk Management Policy
  • Safeguarding Policy
  • Whistleblowing Policy

Modern Slavery and Human Trafficking Policy

MannionDaniels does not condone modern slavery and human trafficking and has developed a policy which details measures, responsibilities and structures for identifying and mitigating risks of modern slavery in our business and supply chain. It applies to all of MannionDaniels’ staff, business partners, consultants, suppliers and associates. We also develop and monitor key performance indicators relating to our business operations and modern slavery.

Due diligence policy and procedure

MannionDaniels due diligence policy and procedure helps us assess the fitness of potential suppliers in relation to MannionDaniels requirements prior to entering into a business relationship or contract for services. Our due diligence policy and procedures considers the fact that we operate in environments where there is a high risk of modern slavery and human trafficking. It also assists us to gather information about our supply chain and to build the capacity of our supply chain in relation to modern slavery and human trafficking and other areas. As part of our standard due diligence policy, we conduct the following:

  • Formal interviews to assess the competence and aptitude of candidates against the requirements of a role, ensure they are applying for the role through their own free will and volition and to confirm right to work to work for candidates, including that there no breaches to immigration law.
  • Due diligence assessment and evaluation of our suppliers and consultants using standard questionnaires which cover capacity, financial standing, capabilities, governance, systems, policies and procedures and adherence to their values and codes of practices including on modern slavery and human trafficking. We apply structured and proportionate methodology to identify and assess risks in our supply chain. We also establish baselines upon which to monitor suppliers and agree improvement plans for them, where needed y chain.

Risk assessment and mitigation

MannionDaniels undertakes regular risk assessment to facilitate good decision making in our business operations and throughout the delivery of services. This includes decisions and efforts to mitigate the risk of modern slavery and human trafficking in our supply chain. At a project level, risks are assessed in relation to modern slaver and other risks. This is on-going and standard practice. Risk and exposure are viewed according to these key areas: country, sectoral, business opportunity, and business partnerships.

Procurement Policy

MannionDaniels’ procurement policy outlines our expectations and acceptable practices for the procurement of goods and services on behalf of the company. We work collaboratively with and provide support to our internal teams and suppliers in their compliance with all our requirements and standards on human rights, discrimination and global labour standards.

Global Commitment

Through our work, MannionDaniels is committed to practicing business as a force for social and environmental good. As part of this commitment, MannionDaniels has signed up to the UN Global Compact, a voluntary initiative for businesses that align their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment, and anti-corruption. We are embedding these principles in our day-to-day operations and strategy for future growth.

Measurement of our effectiveness

We take seriously our responsibility to monitor the effectiveness of our policies in this area. MannionDaniels’ whistleblowing policy is publicised widely at corporate and at project level. It presents our commitment to upholding ethical values and practices and promotes a business culture that enables staff, business partners and others to feel comfortable raising concerns without fear of retribution. MannionDaniels investigates complaints about suspected modern slavery and human trafficking. To support this, we have established by an anonymous, free-to-call and confidential whistleblowing service, which allows for the reporting of concerns including on modern slavery and human trafficking through a safe and secure mechanism. All complaints made through the whistleblowing service or other reporting methods are reviewed and investigated. MannionDaniels does not tolerate acts of retaliation against anyone who makes a good faith report of a possible violation, or who participates in an investigation of possible wrongdoing. In addition, we undertake internal reviews of our approach in relation to modern slavery and human trafficking on a frequent basis and have key performance indicators in place for the provision of support and capacity building that we provide to our supply chain.

Training

MannionDaniels requires that all staff are to view a webinar on the business code of ethics. The business code of ethics prohibits human trafficking and forced labour; staff, consultants and business partners are required to acknowledge they have read and understood this and other policies including the modern slavery and human trafficking policy. In addition, staff, consultants and business partners are required to complete training on evolving areas of compliance on a regular basis. We use short training videos, webinars and in-person training sessions to reach staff, consultants and business partners. MannionDaniels is presently developing training content to cover a number of compliance areas including modern slavery and human trafficking.

If you require a signed copy of this statement, please email us