Milestone Global Resources Ltd
Modern Slavery and Human Trafficking Statement
Milestone Global Resources Ltd is committed to:
- Undertaking and promoting ethical practices and policies to prevent modern slavery and human trafficking (Modern Slavery);
- Ensuring its personnel and assets are not involved or exploited for the benefit of those involved in such activities; and
- Providing a full statement as required under the transparency provisions of the Modern Slavery Act 2015.
The Modern Slavery Act requires that organisations take steps to address modern slavery and human trafficking in their businesses and supply chains. As Milestone Global Resources Ltd has a turnover of less than £60 million, we are voluntarily publishing this statement setting out what we have done to recognise and prevent potential incidences of modern slavery.
Scope
This policy is applicable to all employees (both salaried and hourly paid), workers, contractors, applicants, suppliers and clients.
Organisational Structure
Milestone Global Resources Ltd is the trading name of Milestone Global Resources Ltd, a company registered in England and Wales with Company No.: 10214949. Milestone Global Resources Ltd (MSGR) undertakes sourcing, acquiring, developing, managing and refinancing premium graded property projects; whereas, Milestone Global Resources Ltd is a property-owned subsidiary responsible for managing Real Estates through Semi-independent accommodation and support, Service Apartment Accommodation (SAA), HMO, Emergency and Temporary Housing end users. Milestone Global Resources Ltd mission is to work with people to make choices, achieve goals and take control of their lives through high quality care, support and housing. This is in line with our values of: excellence; aspiration; partnership and trust.
Responsibility
As an employer, we have a responsibility to comply with the Modern Slavery Act, ensuring we have the correct procedures in place to maintain this.
Managers have a responsibility to follow, lead and therefore ensure their teams conduct themselves in line with this policy. They also have a responsibility to communicate and monitor the operation of this policy within their area of responsibility.
All individuals, employees, workers, contractors, applicants, suppliers and clients have a responsibility to assist the Company in meeting the requirements of the Modern Slavery Act by providing truthful information when required, to meet the terms of this Policy and to report any known acts that are in breach of this Policy.
What is Modern Slavery?
Modern Slavery is a form of organised crime whereby people are exploited for criminal gain. Victims can be reluctant to come forward for fear of retribution and consequences from their abusers. The Modern Slavery Act is designed to tackle slavery in the UK, consolidating previous trafficking and slavery offences.
Generally, Modern Slavery can be defined as:
- Individuals being forced to work
- Individuals being owned or controlled
- People being dehumanised
- Individuals being physically constrained or having restrictions placed on their freedom of movement
- Child Labour
We want to be able to demonstrate that we have adequate procedures in place to ensure our employees are able to recognise when Modern Slavery may be in existence. In addition, we want to prevent people associated with the company either exploiting individuals or individuals being exploited. It is important to ensure no employee acts in a way which is inconsistent with our company objectives nor do they undervalue the integrity of the business.
We do not believe it is appropriate for any employees (and persons associated with the Company) to partake in activities which would engage or encourage Modern Slavery on any level. Our Statement below sets out the steps taken by us to ensure Milestone Global Resources Ltd and supply chains are slavery free.
Policies concerning slavery and modern trafficking
All Milestone Global Resources Ltd policies are reviewed and signed off by senior managers on behalf of the Senior Leadership Team where appropriate under a delegated authority from the Board of Management, unless there are particular policies that require Board approval. All policies are reviewed on a rolling basis in response to longevity, audit, statutory or regulatory change and customer and partner feedback.
Milestone Global Resources Ltd response to the Modern Slavery Act has been encompassed in our Safeguarding policy and procedure which identifies modern slavery as a type or pattern of behaviour which constitutes abuse. Additional information on the Modern Slavery Act has also been published and made available to all employees as part of the safeguarding information page of the Milestone Global Resources Ltd (intranet).
The most vulnerable groups in the UK include migrant workers, illegal migrants, asylum seekers and individuals such as homeless people and people suffering from learning difficulties. We are working on identifying how modern slavery and human trafficking may affect our clients, our business and our supply chains. This involves educating staff about potential risks and capturing best practice in policies and procedures.
Procurement
Our procurement processes are designed to ensure that we operate in a legal, ethical and inclusive manner whilst achieving the best value for money. This includes enabling our procurement activity to generate social and environmental, as well as commercial benefits. During 2023/24 we will be further strengthening our procurement processes to ensure our suppliers and contractors must confirm their compliance with the Modern Slavery Act 2015.
All new supply contracts are subject to rigorous risk assessments as part of the risk management process overseen by our internal risk panel. All risks, controls and assurances are signed off by our management team on an annual basis. We include provisions in agreements with our contractors which require them to ensure that they and their supply chains comply with the Modern Slavery Act 2015.
Safeguarding
The Safeguarding policy and procedure requires all Milestone Global Resources Ltd employees and management team to complete mandatory safeguarding training which covers aspects including modern slavery and human trafficking. This is also covered within our safeguarding information leaflet communicated to all customers and employees.
Code of Conduct and Whistleblowing
All Milestone Global Resources Ltd policies emphasise our commitment to dignity at work and fair treatment of all colleagues. We have reviewed our Raising Concerns and Whistleblowing policy and procedure and Code of Conduct to ensure they are compliant with the Modern Slavery Act 2015.
Recruitment
We have reviewed our recruitment and selection policy and procedure to ensure it contains all relevant requirements in relation to eligibility to work in the UK, as well as carrying out of necessary checks such as DBS (Disclosure and Barring Service). We are committed to paying all Milestone Global Resources Ltd employees either the London Living Wage or UK Living Wage Foundation rates as a minimum for their basic salary.
Investigations/due diligence
An Individual Director or Senior Manager with assistance from our Safeguarding Panel is responsible for investigating any suspected instances of modern slavery and human trafficking. This is in line with our standardised response to any reports of safety or serious incident.
Training
All staff, and management team, are required to complete an e-learning module on modern slavery and human trafficking, which is part of the Safeguarding module. A briefing on modern slavery and human trafficking is also available for all staff on the Milestone Global Resources Ltd Hub (intranet). This provides background information and advice about how to raise a concern if they suspect slavery, human trafficking, forced labour or domestic servitude are taking place. Modern slavery is also incorporated into our safeguarding e-learning; safeguarding training; staff induction and manager’s induction.
Supply Chains
The Modern Slavery Act requires that organisations take steps to address modern slavery and human trafficking in their businesses and supply chains. Milestone Global Resources Ltd supply chains are drawn mainly from the property maintenance and services sector as well as the adult social care market.
Milestone Global Resources Ltd operates in London and the South East and has an annual turnover of less than £60.0 million. Milestone Global Resources Ltd has assessed the risks of modern slavery and human trafficking associated with
these sectors as follows
Effectiveness Milestone Global Resources Ltd will continue to provide training to relevant staff to ensure that they understand the potential risks of Modern Slavery in delivering our services and managing our supply chain. This statement is made under section 54(1) of the Modern Slavery Act 2015. It constitutes Milestone Global Resources Ltd slavery and human trafficking statement for the financial year ending 31st March 2023. This statement has been approved by the management of Milestone Global Resources Ltd who will review and update it annually. 14th February 2023 – v2 Modern Slavery Statement Working from 3 UK offices, Milestone Global Resources Ltd has over 6 employees consisting of Staff and contractors. Milestone Global Resources Ltd supplies a daily workforce within the organisation and organisations across the UK, utilising a large pool of thoroughly vetted procedures for permanent or temporary deployment. Milestone Global Resources Ltd is strategic in its thinking with a responsive approach to future needs, utilising local knowledge, networks and client assessment approaches to ensure supply of the right people at the right time, working with clients to ensure legal and ethical compliance throughout each process. Milestone Global Resources Ltd offers each individual a contract of employment and a contract for service, which reinforces our duty of care to the individual. This helps us to ensure that every individual we engage with is being treated fairly, that they are not being exploited, and has the resources to raise any concerns or issues with us. Milestone Global Resources Ltd also provides a confidential health and well-being programme for all the employees and they can contact and discuss any domestic, whistleblowing, traumatic and health concerns with a trained professional within the organisation. Milestone Global Resources Ltd also equips our employees with the necessary skills and training to recognise and eliminate these practices from the supply chain, by way of Milestone Global Resources Ltd on-boarding processes and ongoing Eligibility to Work, General Data Protection Regulations and Equality, and Diversity training. In addition to providing training to all employees on Modern Slavery awareness and how to escalate concerns in a safe and confidential manner. Milestone Global Resources Ltd also has a number of rules and policies in place to minimise the risk of exploitation and forced labour taking place within our labour pool and supply chains: Milestone Global Resources Ltd operates an Approved Suppliers List. Suppliers are selected and approved using one or more of the following criteria: Potential new suppliers are requested to complete a Supplier Evaluation Questionnaire. This questionnaire asks for proof of the Company’s commitment to adhering to the Modern Slavery Act. Upon return, the questionnaire is reviewed to determine whether they are able to supply them in accordance with company requirements. Review Associated Policies This statement was approved and signed on 14th February 2024 Mr Samuel Abe
The Board, Senior Leadership Team and Senior Management have not been made aware of any issues of Modern Slavery within our business or supply chains. Milestone Global Resources Ltd believes the policies and due diligence procedures in place should be sufficient to prevent or enable early identification of matters which may be of concern. We use Key Performance Indicators to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in our business or supply chains, monitoring the e-learning staff undertake, and these KPIs are reported to the Board of Milestone Global Resources Ltd on a regular basis.
Signed By
Mr Samuel Abe
Managing Director
Milestone Global Resources Ltd
Milestone Global Resources Ltd does not condone Modern Slavery, Child Labour and Human Trafficking in any form and, as such, has implemented policies and procedures to ensure that individuals engaged with us do so of their own free will and are not forced into labour.
This policy will be maintained and reviewed at least annually, on a regular basis by the Human Resources Department.
Managing Director
Milestone Global Resources Ltd