Modern Slavery Policy

Modern Slavery and Human Trafficking Statement


This statement sets out the ERS Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

The ERS Group, including its associated and subsidiary companies, recognises that it has a responsibility under the Modern Slavery Act 2015 to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains

The ERS Group is a forward-thinking organisation providing democracy services, from engaging communities to electoral registration, counts and independent scrutiny. It is the umbrella for a group of companies with unrivalled experience in governance, engagement, election and voter registration services. The Group provides a complementary range of services including election services, membership engagement, election management software, governance systems and election supplies.

We work with thousands of organisations in the public and private sectors, from local authorities, political parties and trade unions, to charities, the NHS, membership organisations and professional bodies. The ERS Group is a Civica Group company, employing over 200 people throughout the Group. Our head office is located in London and our subsidiaries – Membership Engagement Services, Xpress Software Solutions, Modern.Gov and Shaw’s – are located in London, Gloucestershire, Hampshire and Kent respectively.

Our supply chains

Our supply chains include printing and paper services, IT services, training providers, recruitment consultants, marketing services, and facility providers amongst others. We have reviewed the risks that these supply chains can present.

We expect our suppliers and contractors to demonstrate a zero tolerance approach to slavery and human trafficking. Suppliers are required to demonstrate that they act ethically and within the law in their use of labour. Where suppliers are unable to demonstrate this standard, we will look to terminate the business relationship. The Group directors are responsible for compliance in their respective companies/departments and for their supplier relationships.

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • HR Policy – We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally, and are paid at least the national minimum wage. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 48 hours per week average unless the employee agrees.

  • Purchasing Policy – The organisation is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls including but not limited to the ERS Group’s ‘Quality Management’, ‘Environmental’, ‘Ethical Code of practice’, ‘Anti-Bribery’ and ‘Modern slavery’ policies which fulfil legal and financial obligations and effectively manages commercial risk. Emphasis is placed on selecting suppliers, goods and services that demonstrate recognisable environmental, sustainable, business integrity along with Corporate Social Responsibility (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation, maintenance and promotion of information security, fair trade and acceptable corporate ethics.

  • Recruitment Policy – The ERS Group uses only specified, reputable employment agencies/consultants to source labour. We ensure that all potential employees have the legal right to work in the UK and that relevant employment legislation is adhered to.

  • Whistleblowing Policy – We encourage all of our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the ERS Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

  • Our Values -All employees of the ERS Group are fully aware of the behavior expected of them when representing the Group and we strive to maintain the highest standards of employee conduct when managing our supply chain.

Due Diligence

The ERS Group undertakes due diligence when considering using new suppliers, and regularly reviews its existing suppliers. Where possible, we build long standing relationships with local suppliers and make clear our expectations of business behavior and expect our supplier to undertake due diligence with, if applicable, their suppliers.

We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Evaluating the modern slavery and human trafficking risks of each new supplier.

  • Use of the Whistleblowing policy in relation to Modern Slavery and Human Trafficking.

  • Reviews of our recruitment and payroll systems to ensure recruitment practices remain legally compliant.

  • Reviews with our direct suppliers to understand the level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations.

  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Awareness-Raising Programme

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff to raise awareness of modern slavery issues.

Training provided to relevant employees includes:

  • The basic principles of the Modern Slavery Act 2015;

  • How employers can identify and prevent slavery and human trafficking;

  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and

  • What external help is available, for example through the Modern Slavery Helpline.

Board Approval

This statement has been approved by the organisation’s board of directors, who will review and update it annually. Our Executive Management team take responsibility for implementing this statement and its objectives. They will ensure adequate resources and investment to ensure slavery and human trafficking isn’t taking place within our organisation or within our supply chains.

Sian Roberts
Chief Executive