MODERN SLAVERY STATEMENT
A) ORGANISATION
This statement applies to all companies within and associated to Gallowglass Security Partners LLP
incorporating Gallowglass Security Limited (referred to in this statement as ‘The Group’).
The information included in this statement refers to the financial year 2024/2025.
B) ORGANISATIONAL STRUCTURE
The Group is a supplier of security services and is regulated by the Security Industry Authority (SIA). It
is comprised of Gallowglass Security Partners LLP incorporating Gallowglass Security Limited.
The LLP wholly owns and manages its service delivery agent Limited. This structure is backed by both
deed and a security support services agreement, and is located at its registered office at 1-5 Beehive
Place, London, SW9 7QR.
Ownership of the Group is vested in three shareowners and the person with significant control is Mr
Giles Turnbull. All members of the LLP have clearly defined roles and take ultimate responsibility for
operations, legal and compliance, finance, HR, H&S, logistics and administration.
They are supported by a middle tier of managers, in these respective spheres of activity, who are
accountable to the members.
Service provision is provided by a pool of SIA licensed guards, who are graded according to experience
and ability into one of three tiers: Security Officer (SO), Senior Security Officer (SSO), and Team Leader
(TL). We select TLs from our pool of SOs and SSOs. Seniority is rewarded by enhanced rates of pay.
The labour supplied to The Group in pursuance of its operations is conducted largely within the M25
area; there is a hub in Greater Manchester that allows us to service demand all points north of
Birmingham in mainland UK.
C) DEFINITIONS
The Group considers modern slavery to encompass:
– Human trafficking;
– Forced work, through mental or physical threat;
– Being owned or controlled by an employer through mental or physical abuse or the threat of
abuse;
– Being dehumanised, treated as a commodity, or bought/sold as property;
– Being physically constrained or having restrictions placed on freedom of movement.
D) COMMITMENT
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to
complying with the provisions in the Modern Slavery Act 2015. The Group understands that this
requires an ongoing review of both its internal practices, in relation to its labour force, and its supply
chains.
The Group does not enter into business with any other organisation, in the United Kingdom or abroad,
which knowingly supports, or is found to involve itself in, slavery, servitude and forced or compulsory
labour. No labour provided to The Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom. See section D post.
E) SUPPLY CHAINS
In order to fulfil its activities, The Group’s main supply chains include those related to manpower,
professional services, vehicles, IT, office hardware, and clothing. Its supply chains are sourced from
the United Kingdom.
F) POTENTIAL EXPOSURE
The Group considers its main exposure to the risk of slavery and human trafficking to exist in labour
provision; rigorous steps have been undertaken to minimise this risk.
In general, The Group considers its exposure to slavery/human trafficking to be relatively limited.
Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the
business of any organisation that supplies goods and/or services to it.
G) IMPACT OF COVID-19
During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For
several months, the UK was placed into lockdown to stem the spread of COVID-19. The Group did not
lock down and continued to trade, but with control measures introduced on all sites and at head office
to mitigate the risk of transmitting the virus.
The Group concludes that the COVID-19 pandemic did adjust the risk of modern slavery to a level
above that which existed before the pandemic, which is set out under section F ante.
During the pandemic, The Group’s employees still had access to the grievance procedure to raise any
concerns that they may have had.
The Group took the decision from the outset of the pandemic to ensure that all of the workforce
who were required to self-isolate in accordance with public health guidelines continued to receive
full pay during their absence.
The Group’s modern slavery risks were subject to the same monitoring procedures during the
pandemic as at all other times.
H) STEPS
Though not required to by law, The Group will, since the formal inception of this policy, extend to all
non-manpower suppliers (we have had independently verified employee safeguards in place since
2007 to prevent modern slavery in our manpower supply chain) due diligence processes in relation to
ensuring slavery and/or human trafficking does not take place in its supply chains, including
conducting a review of the controls of its suppliers.
The Group has not, to its knowledge, conducted any business with another organisation which has
been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has operated British
Standard 7858:2021 (security screening) to ensure that modern slavery does not in any way feature
in our workforce.
The measures pursuant to this standard are as follows:
– ID verification and right to work check (pursuant to the Asylum and Nationality Act 2006
– the first and most well-used checks in pre-employment screening, being critical for all
employment in the UK). These checks must be accompanied by copies of original
identification documents such as passport, driving license and/or birth certificate.
-Obtaining bank details which must correspond to the applicant and not a third party or
third party organisation.
– A 5 or 10-year written career history – which involves an analysis of all periods of
employment, as well as confirmation of employment gaps of up to 31 days. It also
includes analysis of any periods of self-employment.
– A financial probity check (includes bankruptcy, IVA and insolvency checks, and checks for
CCJ’s up to £10,000).
– Criminal records screening to a level of Basic disclosure, which details unspent criminal
convictions and conditional cautions.
– Global watchlist check (cross-referencing the individual’s name(s) against various
sanctions, watchlists and fraud databases, including, but not limited to, the HM
Treasury’s consolidated list of financial sanctions targets in the UK).
– The information gathered as part of the BS7858 is kept for 7 years after the end of
employment.
Our compliance with this standard is undertaken annually pursuant to our ISO 9001:2015 and
ACS annual renewal surveillance visit, when all our processes are subject to an independent
inspection from a UKAS approved assessing body.
Additionally, we propose to undertake a due diligence review of all of our suppliers to confirm
what measures they have undertaken to prevent slavery within their organisations and supply
chains.
We will review our supplier contracts to include termination powers in the event that the supplier is,
or is suspected, to be involved in modern slavery.
We will extend training for all staff members on how to identify potential evidence of slavery and
trafficking amongst applicants and within the workforce.
I) POLICIES
The Group has the following policies which further define its stance on modern slavery, particularly in
relation to the workforce, where all employees are on Peninsula HR employment contracts in which
their statutory employment rights are enshrined. This includes a robust grievance policy.
J) TRAINING
The Group will provide the training to all staff, so they know how to recognise signs of modern slavery
and to whom it should be reported; as well as implementing its stance on modern slavery. The slavery
syllabus will be devised by our in-house trainers, who are both professional ex-teachers, and will be
delivered in person through toolbox training.
J) SLAVERY COMPLIANCE OFFICER
The Group has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should
be addressed, and who will then undertake relevant action with regard to The Group’s obligations in
this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be
reviewed for each financial year.