Modern Slavery statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that it has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Watchstone Group plc (“WTG”) has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

WTG owns varied businesses which are all committed to the improvement and development of solutions that meet the challenges of their markets. Those businesses include:

ingenie

ingenie is an insurance brand focused on helping young drivers get on the road safely and affordably based in the UK.

pt Health

pt Health is a national healthcare company that owns and operates physical rehabilitation clinics across Canada. Its InnoCare subsidiary is an innovative health tech company based in Canada that provides software as a service and business process outsourcing for clinic owners.

Risk areas

WTG and its subsidiaries do not operate in high risk slavery and human trafficking business sectors such as agriculture, construction, retail or businesses employing transient migratory workers. Nevertheless, WTG is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help. It has been circulated to all employees of WTG and its subsidiaries.
  2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK and Canada checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Suppliers

Whilst the Company exercises a vital role in our outsourcing services and software solutions distribution chain, it does not have a supply chain that is largely reliant on factories or other entities that would normally be associated with slavery or forced labour. As a general rule, contractors and suppliers used by the Group are therefore not likely to be susceptible to this risk. However, we understand that others may not always uphold the same standards. Consequently, employees responsible for managing suppliers and others involved with the Group are, themselves, responsible for ensuring that our values are upheld. For example, serious violations by suppliers will lead to the termination of the business relationship.

WTG conducts due diligence on all suppliers before allowing them to become a supplier.  This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery.

Training and recruitment

We conduct training for our employees (where necessary) so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

The Group uses only specified, reputable employment agencies to source labour. All entities in the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports.

The Company and its associated subsidiaries do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all workers to enjoy, include:
• The right to a reasonable wage
• The right to a safe working environment
• The right to an appropriate level of holiday and cover for period of sickness
• The freedom to complain directly via our whistleblowing policy free of charge, if they believe that they are not being fairly treated or have any other concerns.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
  • Reports that are received from employees are investigated thoroughly and reported to the relevant authorities (if necessary).

Approval for this statement

This statement was approved by the Board of Directors on 28 November 2017