Introduction

This statement sets out Absolute Interpreting and Translations Ltd.’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.

As part of the Language Services sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Absolute Interpreting and Translations Ltd:

  • The provision of face-to-face interpreting services.
  • The provision of remote interpreting services.
  • The provision of Translation services.
  • The development of software and hardware innovations to facilitate language services.
  • The carrying out of administrative office activities, including the maintenance of a telephone support centre, HR department and finance desk.
  • The maintenance of a supply chain for routine office supplies, including paper, stationery, office furniture and electronics.

Countries of operation and supply

The organisation currently operates in the following countries:

  • The United Kingdom – Absolute Interpreting and Translations Ltd provides Interpreting and Translations services through a country-wide web of linguists who are contracted to provide services for Absolute’s clients. These are primarily public sector bodies based in England.

The following is the process by which Absolute assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Activities:
    • Level of communication and exposure to company management.Possibility of identity fraud.Possibility of operation outside of the UK.Risk of coercion.
    • Risk of wage appropriation following labour.
  • Country Operation:
    • Robustness of labour laws.
    • Consistency of legal enforcement of labour laws.
    • Prevalence of criminal enterprises.
    • Legal regulation of supply chains.

Activity Risk Assessment

The following is the risk allocation of company activities:

Low/no risk:

  • Office administration roles, e.g. HR, finance, telephone support.
  • Face-to-face interpreting.

Moderate:

  • Telephone Interpreting
  • Translation

High Risk

  • None

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: Mr Emal Haidari, Managing Director and CEO.
  • Risk assessments: All members of Absolute Interpreting and Translations have a broad responsibility for preventing modern slavery, not only within the organisation, but wherever Absolute operates. As such, all company staff receive role-specific training on the identification of modern slavery risk indicators. Reasonability for our training design is overseen by Mr Emal Haidari, Managing Director and CEO. Reasonability for training compliance is held by Ms Sohaela Noor, Head of Quality and Compliance.
  • Investigations/due diligence:
  • Overseen by our Complaints and Serious Incidents department.
  • Training: In addition to overall generic training to ensure awareness of modern slavery, we provide role-specific training to on how to identify and address modern slavery risk factors in a manner relevant to each staff member. For example, Interpreters receive training to identify risk indicators that they might see when undertaking assignments in a service user’s home. Similarly, Operational staff receive training on identity verification and interviewing to ensure that all applicants are legitimate and applying of their own free will.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Absolute Whistleblowing policy: Absolute encourages all its workers, customers and other business partners to report any concerns related to the direct activities or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline/complete our confidential disclosure form.
  • Absolute Employee Code of Conduct: Absolute’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Absolute Supplier Code of Conduct: Absolute is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
  • Absolute Human Rights Policy and Considerations: Absolute is committed to upholding Human Rights through both its direct operation and spending power. AS such, we have our Human Rights policy, and Considerations directs our strategy in operating in a human rights compliant manner, e.g. by training our staff to recognise and uphold human rights. For example, by identifying and acting on indicators of forced labour.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • Mapping the supply chain broadly to assess particular products or geographical risks of modern slavery and human trafficking.
  • Evaluating the modern slavery and human trafficking risks of each new supplier.
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
  • Conducting supplier assessments to evaluate their commitment to preventing slavery and human trafficking.
  • Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans.
  • Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular.
  • Enacting sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:

  • Requires all staff/staff working in UK to have completed training on modern slavery within 3 months of enrolment, to be refreshed annually.
  • Undertakes supplier research prior to on-boarding. This may include, verification of a valid modern slavery statement for all qualifying organisations; verifying the organisations state of residence and operation, assessing the robustness of local labour laws; undertaking reputational research, identifying any potential historic breaches of labour laws, indicative of a modern slavery risk.
  • Undertakes annual supply chain mapping, auditing compliance with our ethical supplier code of conduct. This Absolute evaluates continuous supplier compliance with Absolute modern slavery commitments, among other relevant standards.

Training

The organisation requires all staff within the organisation to complete training on modern slavery awareness and modern slavery in relation to their role.

The organisation requires all staff to complete training sessions assigned to them within three months of enrolment.

The organisation’s modern slavery training includes:

  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • What initial steps should be taken if slavery or human trafficking is suspected?
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • What external help is available, for example, through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger Together” initiative?
  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies, and
  • What steps should the organisation take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains?

 Board Member Approval

This statement has been approved by the organisation’s Board of Directors, who will review and update it annually.

Signed
Emal Haidari
CEO
For and on behalf of: Absolute Interpreting and Translations Ltd