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Modern Slavery Statement

This statement is published in accordance with the UK Modern Slavery Act (the Act). It outlines the approach we take to prevent modern slavery in our business and supply chains. We recognise that Modern Slavery is a growing global issue and are committed to eradicating the risk of modern slavery in our supply chains and operations. We welcome the enhanced transparency and focus that the Modern Slavery Act will bring to the efforts of UK businesses in combatting this crime. Although this is our first Modern Slavery Statement, during the past year we have put in place an Anti-Slavery and Human Trafficking Policy. We have also identified key steps which we intend to take and these are explained in more detail below.

At Communications Plus Ltd, we do not tolerate (directly or indirectly) child labour, threats, coercion, abuse, violence or intimidation among our employees or in our supply chain.

About Communications Plus Ltd

We are a UK based independent franchise of O2 (Telefónica UK Limited), we sell O2 products and services under the O2 brand in line with O2’s instructions. Being independent means we can provide our own extra level of personal care and support both in our shops and at our O2 Business Centre, and have the strength of the O2 network, products, services and infrastructure supporting us.

Communications Plus Ltd is proud to have have opened its first O2 store in Bolton in 2006. Today our Franchise operates twenty O2 shops mainly in the North West but also in North Wales and North East England. Our head office is based in Merseyside which includes our O2 Business Centre which is the home of our consumer sales, B2B sales and supporting teams.

Our People.

At Communications Plus Ltd, we are committed to inclusion, diversity and providing opportunities for everyone. From sales to head office, our success would not be possible without the hard work of our people, which is why it is so important we invest in and develop them. We believe in developing a culture in which our people are treated with dignity and respect at all times.

We aim to create an environment of open and honest communication with everyone having the opportunity to have their say. We know that a motivated and engaged team of people in our stores is vital when building a great place to work.

We have been assessed by Investors in People to measure our overall culture which includes our structure and discipline within the business, which has resulted in Communications Plus Ltd receiving two consecutive ‘Investors in People’ Gold awards.

One key component of building a great workplace culture is ensuring that our people are able to speak freely and openly about any concerns or worries. We are always looking for ways to improve the communication between Communications Plus Ltd and our people. Current examples include:

  • Employee Engagement Survey – feedback from our people is a really important way of understanding how they feel about coming to work. We send out an employee engagement survey once a quarter, which is anonymous, to understand our people’s views and concerns. We then make an action plan to address the main items and improve the working environment.
  • Workplace Forum – we have established a forum which meets once a quarter. Each team has a nominated representative (Guardians). This is to increase worker voice representation to raise and resolve issues. Guardians are provided with training on how to collect suggestions from all employees and how to report back on outcomes from the Forum meetings. The Forum meetings are recorded with agendas and meeting minutes and followed with a process which ensures that any concerns are rectified via an action plan drawn up after the meetings.
  • Whistleblowing policy – The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. This policy protects anyone who raises such concerns.

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.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place an Anti-Slavery and Human Trafficking Policy.

Our Anti-Slavery and Human Trafficking Policy reflects our commitment to implementing and enforcing effective controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains.

Communication Plus Ltd’s supply chains

As a franchise, we only sell products procured by O2 (Telefonica UK). Therefore, all related supply chain risks are managed by O2. O2 have a clearly outlined Supply Chain Sustainability Policy. We conduct our business in accordance with applicable legislation and regulations. 

We also procure local goods and services to support our general business needs and functions. Where possible, we have built and maintained longstanding relationships with trusted suppliers/contractors, making clear our expectations of business behaviour. We expect our suppliers to adopt the same zero tolerance that we do to modern slavery.  As part of our procurement process, any potential contractor or supplier is required to confirm that they comply with all applicable laws and regulations, including the Act.

We would never knowingly engage with suppliers or contractors involved in slavery or human trafficking.

Assessment of Modern Slavery risk within our supply chain

We intend to perform a thorough risk assessment of our operations and supply chains in order to ensure that our efforts towards combatting modern slavery are targeted towards the highest risk areas. We intend to base this risk assessment not only on our own understanding of our supply chains, but also on publically available research and information which identifies particular industries and countries which pose the biggest risk of human trafficking and modern slavery.

We believe that there is minimal risk in our supply chains.  However, we are continuing to improve our processes, include reference to our zero-tolerance approach in relevant documentation with suppliers and also continue to encourage our employees to report any concerns that they have.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chain, we provide a training course on business principles to all our staff.

Communication Plus Ltd’s action plan

We will continue to strengthen our approach to managing the risk of modern day slavery within our business and supply chains and ensure our strategy is responsive to changing risks. We will work with our suppliers to ensure our policy is effective in managing risk and driving improvements within our supply chain.

Modern slavery is a very complex issue, which is often a result of a number of factors, and can be difficult to identify. As our understanding of the causes of modern slavery grows, and our policies and procedures develop further, we are likely to identify additional places where the risk of modern slavery could exist. We recognise that we will need to continually develop our policies and procedures, in order to ensure that we can be as effective as possible in identifying and remedying any incidents of modern slavery that may occur.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30th November 2018.
Stephen Roberts

Communication Plus Ltd