Modern Slavery and Human Trafficking Statement


Four Eyes Insight Ltd is committed to preventing modern slavery and human trafficking in every part of its business and supply chain.

In accordance with the Modern Slavery Act 2015, Four Eyes Insight Ltd is required to prepare a slavery and human trafficking statement for each financial year. The statement sets out all potential modern slavery risks related to the business and the steps taken during the financial year to ensure, that slavery and human trafficking is not taking place in any of its supply chains or in any part of the business.

Four Eyes Insight Ltd commitment to the principles of The Modern Slavery Act 2015
Four Eyes Insight Ltd recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking. As an equal opportunities employer, Four Eyes Insight Ltd is committed to creating and ensuring a non-discriminatory and respectful working environment for all its staff.

Four Eyes Insight Ltd policies
Four Eyes Insight Ltd operates the following policies and manuals 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.

The company’s recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the United Kingdom and to safeguard employees from any abuse, coercion or exploitation.

The following policies are accessible to all staff via our staff handbook on SharePoint:

Modern Slavery and Human Trafficking Standard
The Modern Slavery and Human Trafficking Standard sets out the minimum acceptable levels of behaviour required of all staff, as well as setting out the activities that will be undertaken to identify and address the risk of modern slavery within Four Eyes Insight Ltd and its supply chains.

Whistleblowing Policy
Our Whistleblowing Policy is communicated to employees during their HR induction in their Staff handbook saved in our SharePoint system, which is accessible to all of our employees.

The intention of the policy is to outline the process for employees to report instances of corruption, malpractice, criminal behaviour and failure to deliver proper standards of service, where confidentiality is required. This policy is integral in preventing occurrences of modern slavery and human trafficking by providing an avenue whereby any suspected instance can be reported without fear of repercussions.

The whistleblowing facility is always available to employees and any implications in terms of modern slavery can be brought to attention by any employee anytime. Four Eyes Insight Ltd encourage all employees to report any concerns related to the direct activities, or the supply chains of the organisation.

NDA Supply Chain
We have an NDA in place to ensure suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law. Four Eyes Insight Ltd work with suppliers to ensure they meet the standards of the code and improve their employees working conditions. However, serious violations of the organisation’s code of conduct will lead to the termination of the business relationship.

Conditions of Employment
The Conditions of Employment establishes conditions, processes, protocols, rights and responsibilities governing the employment of all employees. This extends to equal opportunities, pay, working hours, training and development, conduct and discipline and employee relations. This forms part of the contract of employment between Four Eyes Insight Ltd and its employees. The establishment of regulated working practices alongside standards to be upheld ensures the just and fair treatment of all employees.

Standards and Expectations
Four Eyes Insight Ltd makes it clear to employees the actions and behaviours expected of them when representing the organisation. This includes, but is not limited to, competence, reporting, personal responsibility, procedural use and adherence and equality, diversity and inclusion. Upholding these standards within the workplace is essential in ensuring the correct treatment of workers as well as the workers themselves maintaining the highest standards of conduct and ethical behaviour, whether operating at home, abroad or in managing the supply chain

Equal Opportunities Policy
The Equal Opportunities policy documents commitment to providing equal opportunity for employment, advancement and equitable treatment, whilst outlining the responsibilities of employees and their managers to avoid and report instances of harassment. Our commitment to overcoming any barriers to equal opportunity and complying with its obligations is emphasised and this helps to ensure the fair and equitable treatment of all employees by providing a consistent approach to developing the skills and attributes of all employees whilst valuing their respective abilities.

Anti-bullying and Harassment
Our Anti-bullying and Harassment Policy in our staff handbook covers harassment of, and by, all workers engaged to work for Four Eyes Insight Ltd: this includes our employees, contractors, agency workers or anyone working in any other capacity on behalf of our organisation. This policy provides recourse to the disciplinary procedure where an instance of harassment or other occurrences of indecent treatment of an employee occurs. Moreover, the policy sets an expectation of the obligation on employees to intervene in instances of harassment, if they feel able to do so, or at the very least report it immediately to a manager.

The effective action taken to address modern slavery
Four Eyes Insight Ltd will undertake the following activities to address modern slavery risks:

  • Development and roll-out of ethics training to key staff in the organisation and in doing so drawing particular attention to the need to develop positive action in terms of a strong reporting culture and encouraging the use of the whistleblowing facility.
  • Address whether there are modern slavery risks during the contract strategy stage
  • Continue to promote staff awareness of the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking, in line with the requirements of Procurement Policy Note 05/19 – Tackling Modern Slavery in Government Supply Chains
  • Continue to engage with its supply chain to obtain evidence of the controls in place within their organisations to eradicate modern slavery and human trafficking, including looking at the lower tiers of their supply chains
  • Continue with compliance checks as part of the new supplier registration process. This requires suppliers to provide evidence of compliance with relevant legislative, safety, health, environment and quality principles and procedures, where appropriate.
  • Undertake retrospective checks on key existing suppliers to ensure they comply with the requirements of the new supplier process. Where these suppliers fail to do so then engagement shall be required to promote compliance on their part

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Four Eyes Insight Ltd slavery and human trafficking statement for the financial year ending 31st July 2022.