Introduction Per the (UK) Modern Slavery Act 2015 all bodies corporate and partnerships who (irrespective of where they are incorporated) (1) carry on a business, or part of a business, in the UK supplying goods or services, and (2) have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”. This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself. The Republic of Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.
Modern slavery Modern slavery is an international crime affecting an estimated 40.3 million individuals around the world. This global issue transcends age, gender and ethnicities. “Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour. This can then be considered under five headings:
the sexual exploitation of adults;
the trafficking of adults into conditions of labour exploitation;
the trafficking of adults into conditions of criminal exploitation;
the trafficking of minors into conditions of sexual, criminal or labour exploitation;
other forms of exploitation.
“Human trafficking” involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption. Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK and in Ireland who are forced to work illegally against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.
Estimates of the number of victims of modern slavery in the UK and Republic of Ireland have markedly increased in recent years. The 2018 Global Slavery Index estimated approx. 136,000 such individuals in the UK, with approx. 8,000 in the Republic of Ireland.
It has been estimated that globally modern slavery generates as much as $150bn (£116bn) in profits every year with more than a third of these profits generated in developed countries, including the UK and the Republic of Ireland.
Our structure Fónua Ltd was incorporated in Ireland in 1997, initially part of the multinational, UK-based Caudwell Telecommunications Group. In 2000, Eircell (acquired by Vodafone in 2001) purchased a 49% stake in Fónua which Vodafone Ireland retained until December 2016. Following a recent share sale, Fónua Ltd is now 100% owned and controlled by Corstrom Ltd. Fónua ’s directors have a combined 60 years’ experience working at senior level in Fónua . With annual turnover exceeding €300 million, Fónua rank in the Top 250 Companies in Ireland.
Fónua developed into a 4PL service delivery company, providing innovative solutions to a number of customers in the Telecoms industry, including Vodafone Ireland, Tesco Mobile, Post Mobile, eir, Dixons-Carphone and Harvey Norman. Our UK customers include Game, Waitrose, Giffgaff, Jersey Telecom as well as a range of other UK-based retail, insurance and on-line businesses. Core 4PL services provided as standard by Fónua include demand planning & forecasting, procurement & vendor management, supply chain financing, OEM-accredited in-house warranty and non-warranty repair service, warehousing & logistics, customer care, returns management, trade in and refurb services, accessory category management, field marketing and campaign management services.
Our policy The policy of Fónua is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws. If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. Fónua will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.
Fónua is committed to acting professionally and with integrity in all its business dealings and relationships whether in Ireland, UK or abroad.
In this context, Fónua has created a dedicated Anti-Slavery and Human Trafficking Policy.
We will review this policy and its operation in practice, at least on an annual basis.
Reporting knowledge or suspicion of slavery or human trafficking All employees and partners within the firm have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the relevant Engagement Partner and to the Head of Risk, who will decide what further action, if any, is deemed necessary. If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report is to be submitted to the Money Laundering Reporting Officer (MLRO). In addition, the Fónua Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or human trafficking.
Employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.
These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.
Our Anti-Slavery and Human Trafficking Policy also includes contact details for the UK Modern Slavery Helpline, which can be contacted at (0044) (0) 8000 121 700 or via their website at https://www.modernslaveryhelpline.org/.
During the financial year ended 31/12/2019 the Risk, Compliance & Professional Standards Team of Fónua Ireland has not received any reports which relate to knowledge or suspicion of slavery or human trafficking.
Employment procedures Fónua has procedures in place pertaining to our employment practices. • Robust recruitment processes in line with Republic of Ireland employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16). • Market-related pay and reward, which is reviewed annually and linked to professional services firms benchmarks.
Supply chain/ Procurement We recognise that our firm is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However, Fónua considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. In addition, our supply chains are primarily confined to Ireland and the UK, countries with a relatively lower risk of modern day slavery and human trafficking. From a risk management perspective we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking. Fónua is developing additional measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor take-on review and ongoing monitoring process.
Related policies and documents In addition to the Anti-Slavery and Human Trafficking Policy mentioned above Fónua has additional related policies and documents. The Fónua Whistleblowing Policy is highlighted to employees and partners on a reoccurring basis. This policy facilitates and encourages employees to raise concerns or disclose information, which relates to wrongdoing, illegal practices or unethical conduct, which may come to their attention through work (including concerns that may relate to modern slavery and human trafficking).
Fónua have a number of further policies and documents which reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, clients and our business relationships. • Fónua Staff Handbook • Fónua Anti-Money Laundering Compliance Manual • Fónua Anti-Bribery and Corruption Policy
These policies and documents will continue to be reviewed on, at minimum, an annual basis.
Learning We want to help our employees, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.
The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, continues to be flagged in the induction training undertaken by new staff members starting with Fónua Ireland.
We flag each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members.
We are continuing to develop training on the issues of slavery and human trafficking and Fónua’s Anti-Slavery and Human Trafficking Policy, to be delivered to relevant employees and partners on a targeted periodic basis.
Looking forward Fónua will continue to develop the measures mentioned above in respect of our supply chain.
Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2020 and beyond. Fónua shall take responsibility for this statement and its objectives, and it will be reviewed and updated as appropriate.
