Global Modern Slavery Policy
1. Policy Statement
1.1 This policy is a statement of principles outlining Paddy Accelerator's commitment to preventing modern slavery in our organisation. Paddy Accelerator’s aspiration is that all Paddy Accelerator Programmes implement local policies and processes to achieve this in line with local laws, regulations and guidance.
1.2 The Modern Slavery policy aligns with other global policies including Whistleblowing, Safeguarding, Protection of Funds and Anti Bribery & Corruption.
1.3 Paddy Accelerator strictly prohibits the use of modern slavery and human trafficking in our operations. We are committed to acting ethically and with integrity in all our operations and to implementing effective procedures, systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We hold our suppliers, partners and contractors to the same high standards.
2. Purpose
2.1 The purpose of this document is to:
Outline Paddy Accelerator’s zero tolerance approach to modern slavery.
Define the forms that modern slavery can take set out responsibility for reporting.
Set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery.
Provide information and guidance to those working for and on behalf of Paddy Accelerator on how to recognise modern slavery.
3. Scope / Applicability
3.1. This policy is applicable to Paddy Accelerator. It applies to all Paddy Accelerator’s employees, Board Members and volunteers within all regions, areas and functions, wherever located.
3.2. Paddy Accelerator expects partners to adhere to the principles of this policy.
4. Definitions
4.1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking of children or adults, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
5. Actions
5.1. As part of Paddy Accelerator’s initiative to identify and mitigate risk we:
Carry out due diligence checks on partner organisations.
Build long-standing relationships with local suppliers and make clear our expectations of business behaviour.
Have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
Encourage training is provided to relevant staff or volunteers to ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and supply chains.
6. Roles and Responsibilities
6.1 Paddy Accelerator’s Board and Management Team has overall responsibility for ensuring this policy and procedures flowing from this, comply with all legal and ethical obligations, and that all those under the scope comply with it.
6.2 Paddy Accelerator’s Management Team implements this policy, monitors its use and effectiveness, deals with any queries about it, and audits internal control systems and procedures to ensure they are effective in countering modern slavery.
6.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and those policies and procedures flowing from this.
7. Reporting and accountability
7.1 The prevention, detection and reporting of modern slavery in any part of Paddy Accelerator’s network or supply chains is the responsibility of all staff and volunteers. Any activity that might lead to, or suggest, a breach of this policy must be avoided.
7.2 The Global Whistleblowing Statement will be of relevance where there are any concerns or suspicions of modern slavery in any part of the organisation, and any such concerns should be reported in line with the relevant whistleblowing procedure, or other relevant local reporting processes as soon as possible.
7.3 Paddy Accelerator and all affiliated Programmes reserve the right to terminate their relationship with third parties if there has been a breach of this policy.
8. Local policies and procedures
8.1. All Paddy Accelerator Programmes must ensure that this policy is complied with, and commit to creating and implementing local policies and processes to support the principles outlined in this policy, which should be acknowledged by all.
8.2. Paddy Accelerator Programmes are encouraged to provide training to all relevant staff or volunteers on local policies flowing from this, and to ensure a high level of understanding of the need for checks to prevent modern slavery.
8.3. Breaches of this policy, or any local policies and procedures, should be taken seriously and dealt with appropriately by Paddy Accelerator.