Slavery and Human Trafficking Statement
Palladium International Limited supports the Modern Slavery Act 2015 in all parts of its business services. We are committed to preventing the existence or prospect of modern slavery within our organisation, and are endeavouring to ensure that modern slavery and human trafficking are not taking place within our supply chains.
This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 and is Palladium’s updated modern slavery and human trafficking statement for the calendar year starting 1st January 2018.
Our structure, business and supply chains
Palladium International Limited is a private limited company registered in England. It is part of the Palladium group of companies which has corporate offices in the United States of America, United Arab Emirates, Nigeria, Indonesia and Australia, and a presence in more than 60 countries across the globe. Our core business services include business consulting, programme and project management, impact investing and capacity building. We work with corporations, governments, foundations, investors and communities to formulate strategies and implement solutions that generate lasting social, environmental and financial benefits.
Our supply chain consists of external businesses, self-employed consultants and business partner organisations located within the UK and overseas. Due to the nature of our work, we recognise that some of our supply chains operate in high-risk environments for modern slavery including countries with high levels of poverty, a lack of awareness and understanding of human trafficking and modern slavery and weak national systems to monitor and respond to human rights abuses including incidences of modern slavery. Across our operations, we strive to ensure that all goods and services we supply to clients are free of modern slavery through diligent policies, guidelines and mechanism to detect and prevent modern slavery.
Our Policies on Modern Slavery
We are committed to doing all that we can to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Our Company Code of Conduct and Business Partner Code of Conduct describe Palladium’s expectations of its employees and Business Partners when conducting business around the world. Employees and Business Partners must operate worldwide in a manner fully consistent with the highest standards of conduct including following best practices pertaining to integrity and ethics, anti-discrimination and child protection, human trafficking, health and safety, anticorruption and other areas in order to promote good governance and positive impact.
Through our contracts and supply chains, we expect our employees and business partners to obey the law, observe regulations and guidelines and be seen to do so. We have sought to embed this approach within Palladium International Limited business through compulsory code of conduct training for all our employees.
As we work in countries where English in not the primary language, we also provide these policies in Bahasa, French, Spanish and Tetum.
Our Due Diligence Policy and Guidelines
Palladium International Limited has a Due Diligence Policy that applies to all our business activities. Palladium conducts due diligence on all parties that it enters into business relationships with. Our due diligence policy reflects the fact that many of our operating environments are high-risk for slavery and human trafficking.
In addition, Palladium’s Due Diligence Guidelines provide further information on the Due Diligence Policy including when a high security due diligence must be performed based on high risk countries and high risk industries. The purpose of our due diligence process is to ensure we are able to make an informed and transparent decision about whether or not to associate with a business partner.
Palladium aims to embed respect for human rights and zero tolerance of modern slavery in all our business practices. All our corporate and project offices are required to prominently display whistle-blower posters that provide a confidential hotline for our employees, clients, business partners, subcontractors and other third parties to voice any concerns that they have, including concerns about slavery and human trafficking. Our Whistle-blower Protection Policy and Whistle-blower Allegation Guidelines provide further detail on how we handle all whistle blower allegations of misconduct.
Palladium is implementing new due diligence and supplier mapping processes which will include the auditing of suppliers in high-risk environments on their business activities and employment and procurement policies. We will work with suppliers to improve their own policies.
Palladium is updating its risk assessment policy to allow us to estimate the potential risk of modern slavery and human trafficking in our business development pipeline. This will help to inform our decisions and efforts to mitigate the risk of modern slavery and human trafficking in our supply chain.
Palladium International Limited has set up a working group to review all of our current guidelines and practices in relation to modern slavery with the view to improvement. We are developing 2018 KPIs for Senior Management related to the implementation of our policy on modern slavery and our commitment to the Modern Slavery Act 2015.
We will also be taking steps to increase awareness of modern slavery amongst our staff and partners through a compulsory training conducted by third parties and in house teams. We will continue to work to identify opportunities to eliminate modern slavery and human trafficking within our supply chains operations.
Chief Executive Officer and Director
Palladium International Limited
1st December 2017