GATELEY (HOLDINGS) PLC modern slavery statement summary (2022)

Organisation address
One Eleven,
Edmund Street,
Birmingham,
B3 2HJ

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.
Link to full statement
Go to full modern slavery statement on organisation’s website

PDF version of the statement (optional)

Warning The file has been uploaded directly by GATELEY (HOLDINGS) PLC and has not been reviewed, assessed or moderated by the Home Office for suitability and accessibility.
If you need an accessible version of this PDF file, please contact GATELEY (HOLDINGS) PLC for further assistance.
Download

Modern Slavery Statement.pdf

File uploaded: 08 November 2022 at 7:34pm
PDF | 325.49 KB

Download file

About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Organisations covered by the statement

GATELEY (HOLDINGS) PLC modern slavery statement for 2022 is a group statement covering 10 organisations. See the full list of organisations covered by this statement

Statement period and sign-off details

The statement covers the following period:
1 May 2021 to 30 April 2022

The statement was signed off by:
Neil Smith (Finance Director)

It was approved by the board (or equivalent management body) on:
21 October 2022

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Professional and administrative services and supplies, including legal, consulting and accounting services

Turnover

Its turnover in the financial accounting year of this statement was:

£100 million to £500 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
More than 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Policy provisions we asked about Organisation’s response
Freedom of workers to terminate employment Included
Freedom of movement Included
Freedom of association Included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Included
Prohibits compulsory overtime Included
Prohibits child labour Included
Prohibits discrimination Included
Prohibits confiscation of workers' original identification documents Included
Provides access to remedy, compensation and justice for victims of modern slavery Included
Other
Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation Yes
Your front line staff No
Human resources No
Executive-level staff No
Procurement staff No
Your suppliers No
The wider community No
Other
No

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups No
Civil society organisations No
Professional auditors No
Workers within your organisation Yes
Workers within your supply chain Yes
Central or local government No
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector No

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Organisation’s response
The organisation told us it did not carry out any social audits during the period of the statement.

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app Yes
Through trade unions or other worker representative groups No

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
Organisation’s response
The organisation did not answer this question.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Migrant workers in international territories producing promotional items.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
Who was it most likely to affect Organisation’s response:
  • Migrants
  • Refugees
  • Children
In which country Organisation’s response:
  • China
  • India
Actions or plans to address this risk Organisation’s response: We only work with suppliers of promotional items that take an active role in managing the modern slavery risk within their supply chain and sign up to our responsible procurement requirements.

Priority risks for this organisation (2 of 3)

Undocumented workers in the hotel/ hospitality sector within the UK working at venues which we attended for events or conferences.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: Through our training we are made aware of the signs of modern slavery and to be vigilant at events etc of venue staff who may be victims of modern slavery and what to do if we have concerns. When booking venues/ appointing suppliers in the hospitality space, we only work with suppliers who demonstrate compliance with our responsible procurement policies.

Priority risks for this organisation (3 of 3)

Migrant workers in the cleaning of our offices.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: We work with an established cleaning company that can demonstrate that they employ people in the correct way. They also sign up to our responsible procurement protocols.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
ILO indicators we asked about Organisation’s response
Abuse of vulnerability Yes
Deception Yes
Restriction of movement Yes
Isolation Yes
Physical and sexual violence Yes
Intimidation and threats Yes
Retention of identity documents Yes
Withholding of wages Yes
Debt bondage Yes
Abusive working and living conditions Yes
Excessive overtime Yes
Other
-

Actions taken in response to finding ILO indicators

We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
Actions we asked about Organisation’s response
Financial remediation, including repayment of recruitment fees No
Change in policy No
Change in training No
Referring potential victims to government services Yes
Supporting victims via NGO No
Supporting investigations by relevant authorities No
Other
-

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks.
Organisation’s response
The organisation did not answer this question.