Modern Slavery & Human Trafficking Statement
Cordel’s Modern Slavery and Human Trafficking Statement for the financial year ended 30 June 2024, made pursuant to the Modern Slavery Act 2015
Cordel is focused on transforming railway infrastructure through innovation and technology. We are a diverse organisation with operations in the UK, USA, and Australia, and we share a common approach driven by our mission and values.
Corporate responsibility is ingrained in Cordel’s culture and woven into the philosophy and values at the heart of our organisation, which underpin everything that Cordel does.
Cordel recognises the importance of protecting the human rights of all people, including those who may be impacted by its business and is committed to the elimination of all forms of modern slavery from its operations and supply chain.
Cordel Policy on Modern Slavery and Human Trafficking
Cordel is committed to conducting business transparently, honestly, openly, and fairly. We seek to operate responsibly wherever we work and engage with our stakeholders to manage our activities’ social, environmental, and ethical impact in the different markets in which we operate.
It is Cordel’s policy that each company within the Cordel Group and each director, officer, and employee of any Group company complies in all respects with all applicable UK laws and (where relevant) local laws of overseas countries, standards and principles relating to modern slavery in each of the jurisdictions in which a Cordel company trades, operates, or has any other activity. Companies within the Group must establish and enforce effective compliance procedures in their supply chains.
Due Diligence in Supply Chains
Cordel’s standard terms and conditions require suppliers to avoid modern slavery practices and comply with Cordel’s policies regarding them. These include the requirement that suppliers conduct proper and detailed checks of any agency or person used by the supplier and the obligation for the supplier to notify Cordel immediately of any actual or suspected non-compliance.
Cordel deploys targeted due diligence following a risk assessment of suppliers based on several factors, including geographic location, business sector and type of product or service supplied. Cordel reserves the right to conduct supplier audits and access supplier premises and records to fulfil its due diligence.
Providers of agency workers and other sub-contracted people are identified as having a higher inherent risk of non-compliance with Cordel’s Modern Slavery and Human Trafficking policy. As a consequence, suppliers that provide agency staff to Cordel are subject to regular compliance audits that include a review of the steps taken by the supplier to avoid modern slavery and human trafficking.
Recruitment Practices
Cordel is committed to respecting fundamental human rights in all its activities. Recruitment processes for direct employees are designed to ensure that no employees are at risk of modern slavery or human trafficking. For example, in the UK, Cordel confirms the identities of all new employees and their right to work, and pays its employees at least the National Living Wage.
Effectiveness
Cordel adopts a zero-tolerance approach to non-compliance with its Modern Slavery and Human Trafficking policy. Any breach of this policy would be regarded as a serious matter and is likely to result in disciplinary action, dismissal, or termination of the trading relationship in the case of suppliers.
Cordel has reviewed all internal processes for effectiveness and introduced several enhancements in the last two years. These include additional training for all its managers who engage with suppliers and for all new employees to supplement the ongoing training set out below for existing employees in Procurement and Human Resources functions. Cordel introduced a confidential service available to all employees to support Cordel’s existing Whistleblowing policy and procedures, maximising the opportunities for all colleagues to access the support and help they need if they suspect any wrongdoing.
Training
All new employees in positions of management and leadership, as well as all new employees in Human Resources and Procurement, are required to complete mandatory training on the prevention of modern slavery and human trafficking. Training focuses on identifying the signs and risks of modern slavery and human trafficking and gives guidance on how to manage compliance with the Group’s policy throughout its supply chain. This training is repeated at regular intervals to ensure that knowledge is updated. All employees are made aware of the Group’s policy, and Cordel encourages all employees to report any concerns they may have regarding modern slavery and human trafficking either to their line manager or via the Whistleblowing policy.
This Statement has been approved by the Board of Cordel Group PLC and signed by the Chairman. It covers all operating businesses and divisions of Cordel, details of which can be found at www.Cordel.ai.
John Davis
Chief Executive Officer
Cordel Group PLC
16th September 2024