Slavery & Human Trafficking Policy

Cagni Williams Associates Ltd is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015. We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.

Although we are not covered by the definition of a large employer in the Act, we are often employed by such organisations who require their own supply chain to address modern slavery issues. We take this seriously and have produced this Statement accordingly.

Our commitment to tackling modern slavery
We believe we have a clear commitment to understanding modern slavery risks; and ensuring that there is no modern slavery in our own business and supply chains.

Our organisational structure and supply chains
We carry out professional architectural services and have a limited supply chain Which we have reviewed carefully and which we regularly monitor.
We operate primarily in the UK and Europe, but can, and do, operate throughout the world. It is our consideration that the highest risk country in which we currently operate is Mongolia and we will take extra care when operating there.

Who has responsibility for anti-slavery initiatives
Edward Williams and Laura Carrara-Cagni have responsibility for all elements of our policy, training and review.

Relevant policies
Our Staff Handbook contains relevant policies on:
• Bribery and Corruption
• Anti-slavery Policy

Due diligence
When considering our supply chain partners, clients and contractors we carry out a matrix review that considers:-
• Geographical location of operations
• Type of partner (mainly professional or manual labour used)
• Type of activity
Anti-slavery and Anti-corruption and Bribery policies are to be provided by our supply chain for every new or renewed agreement.

Overview of key performance indicators
We have reviewed our key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. We:
• require staff to complete training on modern slavery;
• are developing a system for supply chain verification; and
• are reviewing our and their existing supply chains.

Staff training on anti-slavery measures
Due to the nature of our business we do not require some groups of staff to undertake specific training on modern slavery, but we do require an annual review with all staff members to ensure they understand our policy, and commit to uphold it.

This forms a section of our wider ethics training programme (see below).
The last review with all staff took place on:-
• Monday 6th January 2020

Awareness-raising programmes
We aim to raise awareness of modern slavery issues among our employees by regular group discussions and/or circulating emails on the subject.