Modern Slavery Statement 2023

Our Policy

Modern slavery is an abhorrent practice, a hidden crime that affects over 40 million men, women and children from all walks of life and from all around the world, including the UK. It encompasses slavery, servitude, forced or compulsory labour, and human trafficking, and is a serious violation of fundamental human rights, depriving a person of their liberty and exploiting them for personal or commercial gain.

London Stone will not tolerate modern slavery in our business or in our supply chain, and we recognise that high levels of integrity are required in our procurement of people, goods and services. We have introduced a zero tolerance approach to modern slavery and examined our working practices to identify risks and implement effective controls, systems and procedures to prevent and reduce risks accordingly.

We are also committed to ensuring there is transparency in all our business operations and expect the same approach to be taken by all our suppliers, subcontractors and other business partners. Wherever practicable, London Stone will seek to include in its contracts with business partners, specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

London Stone acknowledges that the risk of modern slavery is present in the production and supply of stone, particularly when products are procured from certain high-risk countries; with this in mind, the company is determined to increase its scrutiny and focus in this area and to develop new working practices which reflect the associated risks identified. Whilst the risk assessment undertaken identified the supply of raw materials as our highest risk, we have also looked closely at our recruitment processes and are satisfied that our robust recruitment and employment procedures ensure only a minimum risk exists in this part of our business, the recent training of key staff will reduce this further.

Scope of Policy

1. This policy applies to all persons working for London Stone or on its behalf in any capacity, including employees at all levels: directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
2. This policy does not form part of any employee's contract of employment and may be amended at any time.

Responsibility for Policy

1. The London Stone board has overall responsibility for ensuring that this policy complies with the organisation’s legal and ethical obligations, and that all those under its control comply with it.
2. Marius Catrinoi-Cornea has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries regarding the policy, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy, and are given adequate and regular training on the policy and the issue of modern slavery in supply chains.
4. Comment on this policy is encouraged and suggestions on ways in which it might be improved should be addressed to Marius Catrinoi-Cornea.

Compliance with the Policy

1. All staff must ensure that they read, understand and comply with this policy.
2. The prevention, detection and reporting of modern slavery in any part of the organisation or supply chains is the responsibility of all those working for or under London Stones control. Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3. All staff must initially notify their functional manager, as soon as possible, if it is thought or suspected that a conflict with this policy has occurred, or may occur in the future. This can also be done in accordance with the organisation’s Whistleblowing Policy, details of which are in the staff handbook and the intranet. The person receiving the initial report will take whatever urgent action that may be deemed necessary. All such cases will be brought to the attention of the functional manager by those receiving the initial notification as a matter of urgency. Once the functional manager has been informed of a suspected breach of policy, he/she will assume responsibility for any further actions taken. All actions should be timed and documented and all documentation or other evidence relating to a suspected breach of policy will be collected and retained by Marius Catrinoi-Cornea should further disclosure in criminal or civil proceedings be required.
4. All staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the organisation or supply chains at any level of supply at the earliest possible stage.
5. If a member of staff is unsure about whether a particular act, the treatment of workers more generally, or the working conditions within any tier of London Stones supply chain(s), constitutes any of the various forms of modern slavery, this must be raised with the respective functional manager or the Marius Catrinoi-Cornea.
6. London Stone encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
7. London Stone is committed to ensuring that no one suffers any detrimental treatment as a result of reporting, in good faith, their suspicion that modern slavery of whatever form is, or may be taking place in any part of its own business or in any of its supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If a member of staff believes that they have suffered any such treatment, they must inform Marius Catrinoi-Cornea or Human Resources Director immediately. If the matter is not remedied, and they are an employee, it must be raised formally using the London Stone Grievance Procedure which can be found in the staff handbook or on the intranet.

Communication, Awareness and Development of this Policy

1. Training on this policy and on the risks that London Stone faces from modern slavery in its supply chains will be provided as necessary. Such training will form part of induction.