Environmental policy statement
The Green Piranha Landscaping Ltd is committed to leading the industry in minimising the impact of its activities on the environment.
The key points of its strategy to achieve this are:
Sean McNamara - Director
Documentation of processing activities – requirements
☐ If we are a controller for the personal data we process, we document all the applicable information under Article 30(1) of the UK GDPR.
☐ If we are a processor for the personal data we process, we document all the applicable information under Article 30(2) of the UK GDPR.
If we process special category or criminal conviction and offence data, we document:
☐ the condition for processing we rely on in the Data Protection Act 2018 (DPA 2018);
☐ the lawful basis for our processing; and
☐ whether we retain and erase the personal data in accordance with our policy document.
where required in schedule 1 of the DPA 2018.
☐ We document our processing activities in writing.
☐ We document our processing activities in a granular way with meaningful links between the different pieces of information.
☐ We conduct regular reviews of the personal data we process and update our documentation accordingly.
Documentation of processing activities – best practice
When preparing to document our processing activities we:
☐ do information audits to find out what personal data our organisation holds;
☐ distribute questionnaires and talk to staff across the organisation to get a more complete picture of our processing activities; and
☐ review our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
As part of our record of processing activities we document, or link to documentation, on:
☐ information required for privacy notices;
☐ records of consent;
☐ controller-processor contracts;
☐ the location of personal data;
☐ Data Protection Impact Assessment reports; and
☐ records of personal data breaches.
☐ We document our processing activities in electronic form so we can add, remove and amend information easily.
Sean McNamara - Director
This statement is made on behalf of The Green Piranha Landscaping Ltd pursuant to the section 54(1) of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement. It outlines the steps we have taken as a business to identify and prevent slavery and human trafficking in our own operations and supply chains. We understand our responsibilities and are committed to improving our practices to combat slavery and human trafficking.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and in our supply chains. Accompanying this is our Whistleblowing Policy which provides a system for our employees to escalate slavery and human trafficking issues and breaches of our Group policies. Both policies are reviewed annually. There have been no breaches or suspected breaches of our Anti-Slavery and Human Trafficking Policy reported in 2020.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify, monitor and mitigate against industry risk, business transaction risk and risk in the countries in which we operate, we nominate senior representatives of the business units and functions, who in turn report to the Group Risk and Compliance Committee chaired by the Enterprise Risk Director. We have in place policies and systems across our business; our trading partners; and our supply chains to:- • Identify inappropriate employment practices; • Identify, assess and monitor other potential risk areas; • Mitigate the risk of slavery and human trafficking occurring; • Protect whistleblowers; and • Investigate reports of Modern Slavery.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage applicable within their relevant country of operations. We also have a Supplier Code of Conduct which outlines our expectations. The Supplier Code of Conduct lists Mandatory Policies and we expect Suppliers to adhere to these standards or higher. The relevant managers will monitor and enforce compliance of the Supplier Code of Conduct.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we provide relevant in-house training to our colleagues. Under our Supplier Code of Conduct we also require our business partners to provide regular and relevant training to their staff and suppliers and providers.
We understand that some workers may be more vulnerable to modern slavery during the coronavirus pandemic. The Group adopted government guidelines for Covid-19 secure workplaces and paying statutory sick pay in order to prevent the spread of coronavirus. Our employees have been and continue to have access to our grievance procedures.
3 NEXT STEPS
• Raise awareness of the Anti-Slavery and Human Trafficking Policy and Supplier Code of Conduct with our employees and suppliers.
• Additional training for employees as necessary.
• Integrate any learnings from Covid-19 into our future strategy.
Sean McNamara - Director