Phorm recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We are committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply
chains are free from slavery and human trafficking. 

During this financial year we taken steps to ensure that slavery and human trafficking are not taking place in any of our supply chains or any parts of our own business. We are proud of the steps we have taken
to combat modern slavery and human trafficking. This statement sets out the actions we have taken to ensure our supply chain and our organisation is free from slavery and human trafficking. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our organisation’s slavery and human trafficking statement for the financial year ending 30th June 2021. 

Our Business 
Phorm is a business service company involved in the public and private sectors within the construction industry, specialising in the residential, commercial and industrial fit out sectors, providing design and installation
of electrical contracts. 

Our Supply Chains 
Phorm maintains a preferred suppliers register and research suppliers to make sure none have been convicted
of any offence under the act. 

We ask all suppliers to provide a Modern Slavery and Human Trafficking Statement to ensure they understand their legal obligations under the act. 

We do not feel that we have any high-risk areas in our supply chain but monitor our supply chain at regular intervals throughout the year to ensure this has not changed. 

Policies 
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations: 

Recruitment Policy 
The company uses only specific agencies to supply any temporary staff that are required from time to time. We always verify the practices of any new agency before placing requirements with them. For permanent staff we have a statement that remuneration is above the minimum wage level. We also ensure all employees are eligible to work in the UK. 

Whistleblowing Policy 
The company encourages all employees, customers and business partners to report any concerns related to the direct activities, or supply chains of the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company whistleblowing procedure is designed to make it easy for employees to make disclosures without fear of retaliation. 

Employee Code of Conduct 

The company’s code of conduct outlined in the Staff Handbook makes it clear to all employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct and ethical behaviour when conducting business. 

Due Diligence 

As part of our initiative to identify and mitigate risk we have in place systems to: 

• Identify and assess potential risk areas in our supply chains. 
• Mitigate the risk of slavery and human trafficking occurring in our supply chains. 
• Monitor potential risk areas in our supply chains. Protect whistle blowers. 

Combating Slavery & Human Trafficking 
We use the following key performance indicators (KPls) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains: 

Instances of breaches of the Modern Slavery and Human Trafficking Act – zero tolerance 

Requiring all employees to undergo training on Modern Slavery and Human Trafficking Review all systems for supply chain verification 

Training 
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. Our training covers: 

• We require all employees to watch the Government “Modern Slavery is Closer Than You Think” video. This is available via You Tube and employees are given time to undertake this task. 
• All employees are provided with “Modern Slavery – A Briefing” to read at their leisure. 
• We run training sessions provided by Vinci Works and High-Speed Training which employees undertake online. 
• We monitor the training provided by our suppliers and our business partners. 

Audit and Review 
We will periodically review our internal systems to improve our ability to identify any improvements that may be necessary, this takes place annually. 

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