Modern Slavery Act Statement
This statement was approved by the Directors of VuDu Engineering on 6 April 2023.
Opening Statement
VuDu Engineering runs its activities with integrity and in keeping with societal acceptance and norms. Modern slavery is a complex and multi-faceted crime, and tackling it requires all of us to play a part. VuDu Engineering is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain.
The Modern Slavery Act 2015 requires UK organisations with an annual turnover of £36m or more to report on the steps they are taking to ensure that modern slavery is not taking place in its supply chains, and published with a link to the home page on its website. This includes VuDu Engineering.
Structure of the VuDu Engineering
While VuDu Engineering is a growing micro-business, many of its clients are considered part of the world's largest companies. VuDu Engineering is working towards a better world, and its vision extends to inspiring, informing and influencing our associates and all those impacted by our work. This is achieved through our daily interactions and the values that we uphold.
VuDu Engineering works with a range of suppliers to deliver its activities, including support services, software services, and professional services.
Policies
The VuDu Engineering has an Anti-Slavery Policy in place and offers guidance on whistleblowing in its Guidance Document "Guidance on Whistleblowing," Dated 12 May 2020 (See Annex A). In 2023 the VuDu Engineering undertook a risk assessment to identify its supply chain areas, which might be susceptible to slavery or human trafficking. The risk assessment considered both geographic and sector risk. It determined that as regards its operations and supply chains, and other services.
This review ensured that all suppliers had implemented and held a policy for managing and reporting Modern Slavery. As part of its future strategy, VuDu Engineering ensures that all prospective suppliers are appropriately boarded in line with VuDu Engineering's vision.
Measuring Effectiveness
We have not identified any instances or indications that either slavery or human trafficking occurs in our supply chain. As such, we have not considered it necessary to adopt any formal performance indicators 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.
Training and Awareness for Staff
Our commitment to acting ethically and with integrity is communicated to all Marshall employees as part of the induction process for all individuals. Training on the risk our business faces from modern slavery in its supply chains is provided as necessary. Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 24.
VuDu Engineering has not found any instances of modern slavery in its operations or supply chain.
Annex A: GUIDANCE ON WHISTLEBLOWING
What is whistleblowing?
'Whistleblowing' is defined by the UK Whistleblowing Commission as 'the raising of a concern, either within the workplace or externally, about a danger, risk, malpractice or wrongdoing which affects others'.
For managers, engineers, and associates whose professional lives revolve around risk management, 'risk' is better interpreted to mean 'inadequate quantification and management of risk'. A concern may include something which you may not be directly involved in but become aware of in the course of your work.
What are my obligations if I have such a concern?
Your obligations when you have a concern can be categorised as ethical, professional and legal.
You have an ethical responsibility as an individual to act when you encounter a material and unmanaged risk, danger, malpractice or wrongdoing which adversely affects others.
You have a legal obligation to comply with the laws of the country in which you operate, and in all countries, you will have an obligation to carry out your duties as an individual in a competent manner.
Your obligation to act when encountering something inconsistent with your Code of Conduct arises under that Code, but is not a legal requirement. However, you may become liable in law if you fail to take some action when it is part of your professional duty.
What does the relevant legislation say?
The general principles of this guidance apply in whichever country managers, engineers and associates are working. However, the laws affecting whistleblowing vary widely from country to country. Some countries may have little or no protective legislation in place, or it may favour the state or the employer more than UK or US legislation does.
In considering how to act, the underlying law applicable to you or your employer may be that of the country where you are working, but if your contract of employment is made in England, it is subject to English law. Other combinations of circumstances may create more complexity, and often both English and local law may be relevant.
If you are considering whistleblowing outside the UK, you should ensure that you are aware of local legislation and local culture.
How do I raise a concern?
Managers, Engineers and associates who cannot easily address a concern on their own should discuss it with, or report the concern to, their immediate employer or manager.
If this does not address the concern, you should ensure you know and use the existing company and industry sector regulatory reporting systems. Where there is no whistleblowing policy, you should still try to raise any concern internally. If this approach has not resolved the concern, or your immediate employer or manager is part of the cause, then you are obliged by your institution's Code of Conduct to escalate your concern, which could mean raising it externally.
Provided a genuine concern is raised, and you have a reasonable belief that you are acting in the public interest, UK law offers individuals protection from action taken by an employer for simply reporting a concern.
Your industry may be regulated. You should make use of any reporting systems which have been put in place by, for example the Health and Safety Executive (HSE); Civil Aviation Authority (CAA); Maritime and Coastguard Agency (MCA); Office of Rail and Road (ORR) or other prescribed persons or bodies.
You should not try to use the protection which relevant legislation may offer whistleblowers simply to air or extend a personal disagreement or grievance with your employer.
Where can I get advice?
If the concern is of a legal or HR nature, then advice should be sought elsewhere. In addition to Public Concern at Work (the whistleblowing charity), industry regulators, trades union or employee legal assistance programmes may be able to provide additional help and advice.
If you are in a position of responsibility in an organisation without a clear ethical code of conduct and whistleblowing policy, you should take steps to ensure these are put in place. In the UK, guidance is available from Code of Practice PAS 1998:2008 issued by the British Standards Institute (BSI) in conjunction with Public Concern at Work; the recommended Code of practice in the UK Whistleblowing Commission Report; and the Department for Business, Innovation and Skills' Whistleblowing Guidance for Employers.
Further resources regarding whistleblowing.
We have gathered together some suggested web links and introductory texts for those who would like to explore whistleblowing further.
GOV.UK. Whistleblowing for employees:
https://www.gov.uk/whistleblowing/what-is-a-whistleblower
GOV.UK. Whistleblowing - list of prescribed people and bodies:
ACAS Whistleblowing. Public Interest Disclosure:
http://www.acas.org.uk/index.aspx?articleid=1919
The Public Concern at Work charity's whistleblowing commission:
http://www.pcaw.org.uk/law-policy/whistleblowing-commission
A guide to PIDA: Public Interest Disclosure Act 1998:
http://www.pcaw.org.uk/law-policy/a-guide-to-pida
Martin, M., and Schinzinger, R., 2005. Ethics in Engineering. 4th edition, New York: McGraw-Hill, chapter 6;
Whitbeck, C., 1998. Ethics in Engineering Practice and Research. Cambridge: Cambridge University Press, chapter 3.