Statement on the Prevention of Slavery and Human Trafficking in Xoserve Limited
Xoserve Limited is committed to preventing slavery and human trafficking in its business. This statement sets out the steps that Xoserve has taken to address any risk of slavery and human trafficking taking place within its supply chain or any part of its business.
Xoserve’s organisational structure, business model and supply chains
During the financial year 2016/17 Xoserve was jointly owned by National Grid, National Grid Gas Distribution, Northern Gas Networks, Scotland Gas Networks, Southern Gas Networks, Southern Gas Networks and Wales & West Utilities and was a National Grid subsidiary company.
From 1st April 2017 Xoserve is jointly owned by National Grid Transmission, Northern Gas Networks, Scotland Gas Networks, Southern Gas Networks, Wales & West Utilities and National Grid Gas Distribution.
Xoserve provides central data services for the benefit of the gas industry in Great Britain. It provides a range of services including maintenance of the major gas transporters’ supply point registers, provision of information and enquiry services, allocation of energy, calculation of transportation volumes and charges, transportation invoicing and energy balancing credit management, invoicing and cash collection. Xoserve’s business is only based in Great Britain but some parties which benefit from its services are based overseas. Xoserve also makes significant use of IT services from major companies based in India.
Our policies to address the risks of slavery and human trafficking
Our approach to the risks of slavery and human trafficking can be found across a framework of policies and guidance.
As a subsidiary of National Grid, our employees are expected to follow the principles set out within National Grid’s guide to ethical business conduct, “Always Doing the Right Thing”. This sets out the ethical and conduct codes with which employees are expected to comply. From 1st April 2017, employees have been directed to follow Xoserve’s guide to ethical business conduct, “Doing the Right Thing” which is tailored for Xoserve’s business needs.
In addition, Xoserve has a Code of Employee Conduct which sets out required conduct designed to ensure a safe and efficient workplace and maintain good employment relationships. Whistle-blowers are protected in accordance with the principles set out in “Always Doing the Right Thing” and “Doing the Right Thing”. Hotlines are made available to enable employees to report any concerns in complete confidence.
Our recruitment policies and processes recognise an individual’s rights to work in an environment free from discrimination and to realise their full potential by ensuring equal opportunities at work. All direct employees are paid above the minimum living wage and have appropriate rights to work.
We also have in place a Supplier Code of Conduct which sets out the standards of ethical business conduct we expect from our supply chain. We expect businesses in our supply chain to provide safe working conditions free from harm, intimidation, harassment and fear, treat workers with dignity and respect, and act ethically and within the law.
Our processes to identify and reduce the risk of slavery and human trafficking taking place in our supply chains or operations
In addition to the policies and codes referred to above, in order to identify and reduce the risk of slavery and human trafficking, we operate the following control and assurance framework:
(a) we use the following tools as appropriate when appointing new suppliers:
(i) the Achilles Utilities Vendor Database as a selection tool to ensure suppliers are of an ethical standard. This includes questions on slavery and human trafficking;
(ii) pre-qualification questionnaires; and
(iii) Thomson Reuters World-Check to assist in undertaking supplier due-diligence; and
(b) we include obligations in our contracts with our suppliers requiring compliance with all applicable laws and regulations.
Our ongoing commitment to eradicating slavery and human trafficking
A programme of training and awareness on the Modern Slavery Act 2015, its implications and what it means to day to day working practices is included in Xoserve’s compliance programme. Modern Slavery awareness is included in the induction programme attended by all staff on joining the organisation. Refresher awareness training is given on an annual basis to all staff with relevant updates and awareness throughout the year where appropriate. Training is specifically focussed on identifying and managing the risk of slavery and human trafficking for staff who are engaged in the management of our supply chain, purchasing policies and recruitment practices.
We have an ongoing review group led by our Assurance team which is tasked with reviewing our processes and monitoring compliance.
Approved by Xoserve Limited Board 27th April 2017
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