Anti-Slavery Policy

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people worldwide, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain. At Charkos UK, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business and to implement steps to prevent slavery and human trafficking during the financial year 2019-20.

Our Business and Supply Chains

Charkos UK is a leading healthcare consulting, recruitment, and training company. It operates out of the UK. However, some of its suppliers are from India. We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and onboarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety, and environmental standards, and references. We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers. Still, if we were, then we would act immediately against the supplier and report it to the authorities.

Risk Assessment

In the past year, we conducted a risk assessment of our supply chain by taking into account the following:

The risk profile of individual countries based on the Global Slavery Index
The business services rendered by the suppliers
The presence of vulnerable demographic groups
A news analysis and the insights of labour and human rights groups

This assessment will determine our response and the risk controls that we implement.

Policies

Charkos UK operates the following policies for identifying and preventing slavery and human trafficking in our operations:

Whistleblowing Policy – We encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.

Code of Conduct – Our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Purchasing Code – We have updated our Purchasing Code and supplier contracts to reference slavery and human trafficking explicitly.

Supplier Due Diligence

Charkos UK conducts due diligence on all new suppliers during onboarding and on existing suppliers at regular intervals. This includes:

Assessing risks in the provision of particular services
Auditing the suppliers, and their health and safety standards, labour relations, and employee contracts
Requiring improvements to substandard employment practices
Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

They don’t use any form of forced, compulsory or slave labour
Their employees work voluntarily and are entitled to leave work
They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
They don’t require employees to surrender their passports or work permits as a condition of employment

Awareness

Charkos UK has raised awareness of modern slavery issues by sharing this Policy with all the suppliers and all our staff, which explains:

Our commitment to the fight against modern slavery
Red flags for potential cases of slavery or human trafficking
How employees should report suspicions of modern slavery

Training

In addition to the awareness program, Charkos UK has rolled out a fresh e-learning course to all employees and supplier contacts, which covers the following:

Various forms of modern slavery in which people can be held and exploited
The size of the problem and the risk to our organisation
How can employees identify the signs of slavery and human trafficking, including unrealistically low prices?
How should employees respond if they suspect slavery or human trafficking?
How can suppliers escalate potential slavery or human trafficking issues to the relevant people within their own organization?
What external help is available for the victims of slavery?
What terms and guidance should be provided to suppliers in relation to slavery policies and controls?
What steps will Charkos UK take if a supplier fails to implement anti-slavery policies or controls?
An attestation from Suppliers that they will abide by Charkos UK’s anti-slavery policy

Measuring How We're Performing

Charkos UK has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organization and supply chain. These include:

How many employees have completed mandatory training?
How many suppliers have filled out our ethics questionnaire?
How many suppliers have rolled out an awareness and training program that is equivalent to ours?
How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
What are the findings of our cross-functional Human Rights team?
How are we addressing modern slavery and human trafficking?

This statement covers 1 April 2019 to 20 January 2020 and has been approved by the board of Charkos UK at the board meeting on 20/01/2020

Seema Baliyan
Co-Founder and Director
Date: 25/09/2022