Introduction from the Managing Director – Peter Tillotson
QHS is very clear that modern slavery covers several areas – not simply those born into discrimination and a class-based slavery system. In fact, modern slavery also covers other areas, such as bonded labour, forced migrant labour, child labour and more. The slave trade even takes place in more developed, wealthy countries, such as right here at home, in the United Kingdom and in Europe.
At one end of the chain, modern slavery looks like a migrant worker being forced into labour for fear of losing their passport, or a child being tasked to work in a dangerous factory. Without a doubt, modern slavery is a global concern – one that is not confined to a specific geographical space or a certain social class, but one that is pervasive. That is why governments rightly have worked to introduce new legislation that extends their power to combat traffickers, seize offenders’ assets and control their movements. Here in the United Kingdom, the Modern Slavery Act 2015 was introduced.
As an SME, QHS – Quality Heating Services Ltd believes we can do our bit to protect those most vulnerable and at risk of slavery and human trafficking. We have an uncompromising, zero tolerance approach to slavery or human trafficking. Where if we identify it, we will take robust and decisive action to put it right. Beyond that, where somebody in our supply chain causes a risk that we consider to be unacceptable, we will expect it to be put right.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.
Our business
QHS – Quality Heating Services Ltd has been in business since 1995 delivering gas & electrical installation, repair and maintenance services within the UK. We continue to develop our expertise in energy, renewables and home services and accept our role as an extremely important part of the UK supply chain to larger organisations in these sectors.
We are subject to a strict regulatory regime, meaning that we are inspected on a frequent basis for compliance for technical standards, safety, health and employment rights / DBS etc. as part of our license to operate in the energy sector. We also undertake ongoing internal audit and client supply chain inspections including the use of external specialists to review compliance and identify areas for improvement.
QHS – Quality Heating Services is authorised and registered with various authorities including GasSafe, NICEIC, MOCoPA, Achilles, CHAS, Safe Contractor, BM TRADA and we are an accredited Living Wage employer.
Our supply chain
Our supply chains generally means we procure from within the United Kingdom and European Union. They may procure from outside of these areas as our supply chain is dynamic because of the nature of our business.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due diligence processes for slavery and human trafficking
We have a compliance officer in place to meet our regulatory obligations across our enterprise who is responsible for administering and giving effect to our Quality Management System.
As part of our strategy to identify and mitigate risk we have established into our Quality Management System various procedures. These procedures help us:
- Carry out risk based due diligence on our customers and suppliers before we decide to start a relationship with them.
- Identify and assess potential risk areas in our supply chains including those posed directly by our customers and suppliers.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains through ensuring we only deal with appropriately qualified and approved customers and suppliers.
- Monitor potential risk areas in our supply chains.
- Promote and protect whistle blowers.
Supplier adherence
To ensure all those in our supply chain align with our ethics, we ensure that our suppliers are aware of our expectations. We achieve this through actively communicating with our suppliers, setting the right tone and culture within our organisation and ensuring that we have a robust Quality Management System in place that is inclusive of the requirement to carry out appropriate risk based due diligence on our suppliers.
We have a zero tolerance to slavery and human trafficking within our business. Where we identify that a supplier, customer or another party within our supply chain has not met the high standards we set, we will cease our dealings with them.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff at the point of induction and ensure that they know where to find our modern slavery statement.
We also ensure our staff know who to speak to if they have a concern. We also enable staff to report their concerns confidentiality.
Whistleblowers
We will protect whistleblowers and encourage confidential whistleblowing to assist us protect the supply chain from slavery and human trafficking. Where we identify a need to act, we will do so decisively.
Our effectiveness in combating slavery and human trafficking
We use three indicators to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Co-operate with all lawful requests for assistance by authorities around the globe within 48 hours
- Carry out a review of our supply chain at twice a year with a specific emphasis on modern slavery and human trafficking
- Ensure that this policy statement is reviewed annually by our senior management team
Approval and review
This policy was approved by the board of directors on 4th February 2021. It will next be reviewed in February 2022.