Modern Slavery Act - Transparency Statement 2019
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 for financial year
ending 2020 and sets out the steps that ForViva has taken and continues 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. ForViva
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. We will not knowingly deal with any business involved
in slavery or human trafficking.
We are a social purpose business which operates within the UK that positively impacts
communities by reinvesting profits, building vibrant and safe communities. We know that
together we can achieve more so we work with a range of like-minded partners to deliver
positive change in communities and improve lives. ForViva Group structure comprises of the
The Group has noted the requirements of the Modern Slavery Act 2015 (the "Act"). This
statement is made on behalf of the Group parent, ForViva, and the Group as a whole. The
following subsidiaries in the Group are required to make their own statement under the Act and
have adopted this statement.
• Liberty Group Investments Ltd
In Our Business
Potential risks are mitigated by our policies and procedures, controls built into our business
operations and the knowledge, skills and behaviours of our staff. Our documents that are
relevant to slavery and human trafficking are:
• Anti Corruption and Bribery Policy
• Code of Conduct Policy
• Procurement Framework
• Recruitment and Selection Policy and Procedure
• Child and Adult at Risk Safeguarding Procedure
• Whistleblowing Policy
We will continue to review and update relevant policies and procedures so that we take
effective and proportionate steps to ensure there is no slavery and human trafficking in our
business. We plan to review our Procurement Strategy and Tendering Procedure in 2019.
We require new employees to produce original documentation of their right to work in the UK
on commencement of employment.
We recognise 4 trade unions and support their involvement in respect of employee rights.
We do not operate zero hours contracts and comply with the national living wage requirements.
In Our Supply Chain
We engage with a wide variety of organisations for a broad range of goods and services which
are primarily corporate, construction and property related.
Some of our suppliers subcontract work or rely on recruitment agencies to supply permanent or
temporary staff. Whilst we consider that the risk in our supply chains is low, we recognise that
no supply chain can be considered entirely risk-free.
Our tendering process ensures we engage with reputable contractors and suppliers who
adhere to all appropriate legislation, regulation and practices.
We have not identified any breaches of the Act during 2018. We will continue to be vigilant and
where a compliance breach is identified, we will act promptly, involve the appropriate lead
agencies and feedback lessons learnt in order to minimise the risk of an incident occurring
Training and Awareness
We raised awareness of modern slavery and human trafficking through the publication of this
statement on ForViva and subsidiary group websites.
We may also come across slavery and human trafficking in connection with the customers we
support. In addition, our homes could be used for modern slavery. We have a safeguarding
procedure in place and deliver mandatory safeguard training to raise awareness of what
slavery and human trafficking might look like in our business; and to encourage key customer
facing staff to report concerns.
We will continue to raise awareness and deliver training to new and existing staff on
Safeguarding and will implement a modern slavery e-learning module.
This statement was signed by the Group
Director of Resources
Name: Mike Parkin Date: 9.5.2019
This statement was approved by the Board on: (date) 13th June 2019
Name: Andy Zuntz (signed on behalf of Board)