Modern Slavery

General

Modern Slavery Act 2015 consolidates existing offences of human trafficking and slavery and encompasses trafficking for all forms of exploitation. It does not apply to offences committed before 31 July 2015. The Modern Slavery Act (MSA) 2015 covers four activities:

Slavery	Exercising powers of ownership over a person
Servitude	The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour	Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human trafficking	Arranging or facilitating the travel of another person with a view to their exploitation

Because of our business size, TLB has no legal obligations but we do closely follow the guidance laid out in the Slavery and Human Trafficking Guidance for Businesses in Scotland, https://www.gov.scot/publications/slavery-human-trafficking-guidance-businesses-scotland/

The Company’s commitment

The Lines Between is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. Furthermore, TLB supports the Scottish Government in its goal of working towards the elimination of human trafficking and exploitation. The Trafficking and Exploitation Strategy (https://www.gov.scot/policies/...), published by Scottish Government in May 2017, sets out the following outcomes to be achieved under three key action areas:

• Identifying victims and supporting them to safety and recovery;
• Identifying perpetrators and disrupting their activity; and
• Addressing the conditions, both local and global, that foster trafficking and exploitation.

We recognise that the business sector has a key role in this work and TLB takes the following action in business dealings.

• As an Equal Opportunities employer, we're committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.
• Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
• We do not conduct business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Our supply chain

The Scottish Government has published its mechanisms for guarding against modern slavery in its clients' supply chains and we follow this guidance when dealing with our supply chain. Due to the nature of our business, our supply chains are limited, and we procure goods and services from a restricted range of UK suppliers.

However, we expect the same high standards from all our contractors, suppliers and other business partners. We explicitly prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Our policies in relation to the Modern Slavery Act 2015

The following policies are available to all staff in The Lines Between policy folder and our Employee Handbook:

• Code of conduct
• Ethics policy
• Bullying and harassment policy
• Diversity and inclusion policy
• Recruitment and selection policy

Embedding the principles

We will continue to embed the principles through:

• Awareness:

1) Training staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.

2) Ensuring staff involved in procurement activity are aware of, and follow modern slavery procurement guidance on GOV.UK.

3) Ensuring that consideration of the modern slavery risks and prevention are added to The Lines Between policy review process as an employer and procurer of goods and services

4) Making sure The Lines Between contract terms and conditions include references to modern slavery and human trafficking

5) Staff involved in buying or procurement and the recruitment and deployment of workers receive training on ethical employment practices.

• Prevention:

1) Ensuring, through awareness and good practice, that staff and those who work with The Lines Between minimise the risks of human trafficking and modern slavery.

2) Promote the company’s zero-tolerance policy and actively embed it in company literature and practices.

• Reporting:

All staff and those who work with us are clear on what steps to take where concerns arise regarding allegations of human trafficking and modern slavery. Any concerns or suspected incidents of modern slavery or human trafficking in our work or suspected in our supply chain should be reported to the Managing Director and Business Manager.

• Responding:

Ensure action is taken to address any suspected cases of human trafficking and modern slavery.

To help employees identify cases of human trafficking and modern slavery, the following are examples of prohibited categories of behaviour:

1. chattel slavery in which one person owns another person.
2. Bonded labour or debt bondage which is when a person's work is the security for a debt – effectively the person is on 'a long lease' which they cannot bring to an end, and so cannot leave their ‘employer'. Often the conditions of employment can be such that the labourer cannot pay off their debt and is stuck for life, because of low wages, deductions for food and lodging, and high interest rates.
3. Serfdomwhich is when a person has to live and work for another on the other's land.
4. Other forms of forced labour such as when passports are confiscated (sometimes by unscrupulous recruitment agencies) from migrant workers to keep them in bondage, or when a worker is 'kept in captivity' as a domestic servant. If a supplier or contractor appears to impose excessively harsh working conditions or excessively poor wages, then you should always be alive of the possibility that a form of forced labour is occurring, and take care with your due diligence.
5. Child slavery is the transfer of a young person (under 18) to another person so that the young person can be exploited. Child labour may, in fact, be a form of child slavery, and should not be tolerated. See the Save the Children Child Safeguarding Policy for further details.
6. Marital and sexual slavery including forced marriage, the purchase of women for marriage, forced prostitution, or other sexual exploitation of individuals through the use or threat of force or another penalty.

This statement has been approved by Lorraine Simpson, Managing Director of The Lines Between, for
the year ending December 2026.

It will be reviewed and updated every year.