Compliance & Governance Policies - Modern Slavery & Human Trafficking Policy
Applies to: ARO Management, ARO Technologies, ARO Resourcing Services and associated trading entities
1. Modern Slavery & Human Trafficking Policy
1.1 Policy Statement
ARO Management and ARO Resourcing Services is committed to preventing modern slavery, forced labour, and human trafficking in all its business operations and supply chains. We operate with integrity, transparency, and accountability, and we expect the same standards from our partners, suppliers, and contractors.
1.2 Scope
This policy applies to all employees, contractors, suppliers, agency workers, and business partners of ARO Management and ARO Resourcing Services.
1.3 Responsibilities
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Senior management is responsible for ensuring compliance with this policy.
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Managers must ensure staff understand and adhere to this policy.
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Employees must report any concerns regarding potential modern slavery.
1.4 Risk Assessment & Due Diligence
ARO Management and ARO Resourcing Services will:
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Conduct due diligence on suppliers and partners.
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Include anti-slavery clauses in contracts where appropriate.
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Monitor labour practices and working conditions.
1.5 Reporting Concerns
Any concerns should be reported through the Whistleblowing Policy channels. Reports will be investigated confidentially and without retaliation.
ARO - Anti bribery and Corruption Policy
2. Anti-Bribery and Corruption Policy
2.1 Policy Statement
ARO Management and ARO Resourcing Services has zero tolerance for bribery and corruption. We are committed to conducting business ethically and lawfully in accordance with the UK Bribery Act 2010.
2.2 Scope
This policy applies to all employees, contractors, agents, and third parties acting on behalf of ARO Management and ARO Resourcing Services.
2.3 Prohibited Conduct
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Offering, giving, soliciting, or accepting bribes or improper payments.
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Facilitating payments to secure business advantages.
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Gifts or hospitality intended to influence decisions.
2.4 Gifts and Hospitality
Reasonable and proportionate hospitality is permitted. Any gifts or hospitality over £100 must be declared and approved by senior management.
2.5 Reporting
Suspected bribery must be reported immediately under the Whistleblowing Policy.
ARO - Equal Opportunities & Diversity Policy
3. Equal Opportunities & Diversity Policy
3.1 Policy Statement
ARO Management and ARO Resourcing Services is committed to providing equal opportunities in employment and service delivery. We value diversity and will not tolerate discrimination.
3.2 Scope
This policy applies to recruitment, employment, training, promotion, and service provision.
3.3 Prohibited Discrimination
Discrimination, harassment, or victimisation based on:
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Age, disability, gender reassignment, marriage or civil partnership
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Pregnancy or maternity, race, religion or belief, sex, sexual orientation
3.4 Responsibilities
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Managers must ensure fair treatment and inclusive practices.
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Employees must treat colleagues and clients with respect.
3.5 Complaints
Complaints will be investigated promptly and confidentially.
ARO - Whistleblowing Policy
4. Whistleblowing Policy
4.1 Policy Statement
ARO Management and ARO Resourcing Services encourages employees and stakeholders to report concerns about wrongdoing, malpractice, or unethical behaviour without fear of retaliation.
4.2 Scope
Concerns may include:
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Criminal activity
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Breach of legal obligations
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Health and safety risks
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Fraud, bribery, or corruption
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Safeguarding concerns
4.3 Reporting Channels
Concerns should be reported to:
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Line Manager or Director
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Confidential email: info@aromgmt.com (or designated contact)
4.4 Protection
Whistleblowers will not suffer detriment or retaliation for raising genuine concerns.
ARO - Safeguarding Policy (Children and Vulnerable Adults)
5. Safeguarding Policy (Children and Vulnerable Adults)
5.1 Policy Statement
ARO Management and ARO Resourcing Services is committed to safeguarding and promoting the welfare of children and vulnerable adults in all activities, particularly within youth services and community projects.
5.2 Definitions
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Child: Under 18 years of age
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Vulnerable Adult: An adult who may require care or support services
5.3 Responsibilities
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All staff must hold appropriate DBS checks when required.
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Safeguarding training will be provided to relevant staff.
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Safeguarding concerns must be reported immediately.
5.4 Reporting Safeguarding Concerns
Concerns should be reported to the Safeguarding Lead or senior management immediately. Where necessary, concerns will be escalated to local authorities or police.
5.5 Code of Conduct
Staff must:
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Maintain professional boundaries
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Avoid inappropriate contact or communication
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Never engage in abuse, neglect, or exploitation
6. Data Protection & GDPR Policy
6. Data Protection & GDPR Policy
6.1 Policy Statement
ARO Management and ARO Resourcing Services is committed to protecting personal data and complying with the UK GDPR and Data Protection Act 2018.
6.2 Data We Collect
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Employee and candidate data
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Client and customer information
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Supplier and partner details
6.3 Data Processing Principles
ARO Management and ARO Resourcing Services will ensure data is:
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Processed lawfully, fairly, and transparently
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Collected for specified purposes
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Accurate and kept up to date
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Stored securely and confidentially
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Retained only as long as necessary
6.4 Data Subject Rights
Individuals have the right to:
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Access their data
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Rectify inaccuracies
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Request deletion or restriction
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Object to processing
6.5 Security Measures
ARO Management and ARO Resourcing Services will implement technical and organisational measures to protect data, including access controls and secure storage.
6.6 Data Breach Reporting
Any data breach must be reported to senior management immediately and, where required, to the ICO within 72 hours.
7. Policy Review
These policies will be reviewed annually or when legislation or business operations change.
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