January 2021 | Introduction
Triple Line is committed to the UK Government’s Modern Slavery Act of 2015 and its related implications on the international development sector, notably Goal 8 of the Sustainable Development Goals – Decent Work and Economic Growth.
Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women, or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after (National Crime Agency).
Triple Line has a zero-tolerance approach to modern slavery. We are committed to acting with integrity, promoting this integrity to all whom we work, and to implementing effective systems and controls to mitigate the risk of modern slavery occurring within our business or supply chain. Triple Line does not support or knowingly deal with any business or individual involved in slavery or human trafficking. We will not work with any party that we suspect is connected in any way with slavery or trafficking.
Organisation structure and supply chains
Since 1999 Triple Line has worked as a value-driven organisation to create conditions that stimulate sustainable economic growth and equitable development in poor countries.
We work globally with project teams providing expert technical advice, facilitating new partnerships, providing guidance and project management to help change, shape, and develop societies and economies for the better. Whether it is in urban planning, fund management, governance, climate change, or social development we do this with one goal in mind: delivering lasting results where they matter most.
Since July 2014, Triple Line became part of the IPE Global Group (www.ipeglobal.com) which has its Global Headquarters in India. Today Triple Line operates as a Division of the IPE Global Group with offices in Addis Ababa, London, Manila, Yangon, and Nairobi.
We regularly partner with other consultancy, academic, and research organisations to deliver our work. Our partners are a mixture of other international organisations and local firms based in the countries in which we deliver. We also work with independent consultants who fill specific technical requirements.
Policies in relation to slavery and human trafficking
In support of our commitment to protect against slavery and human trafficking we have several interconnected and complementary policies and process documents. These include:
- Triple Line’s whistleblowing and reporting guidelines;
- Code of Conduct (included in all staff and supplier contracts);
- Human Resources Policy;
- Staff Handbook;
- Duty of Care Policy;
- Safeguarding Policy.
All these documents reflect our core company values and commitment to upholding the highest standards of integrity and respect for everyone whom we work. All policies are reviewed periodically to ensure they remain up-to-date and fit for purpose.
Due diligence processes
All contracts issued to partners, consultants, and third-party suppliers require compliance with the ethical standard described in the Triple Line Code of Conduct and FCDO’s Supplier Code of Conduct. We complete due diligence on all parties prior to contract to validate their credentials and reputation in the industry.
We will be working closely with the Safeguarding Leads Network to explore the applicability of the new UK Government-supported schemes to enable better information sharing within the aid sector of the history and background of individuals. These include Project Soteria, the Misconduct Disclosure Scheme, and the Aid Worker registration scheme.
Risk assessment and management
Triple Line is committed to enforcing anti-human trafficking and anti-slavery practices worldwide. We will only engage with organisations, consultants, and clients who demonstrate a serious commitment to the respect and safety of their workers and operate in compliance with international human rights laws.
A risk assessment and register are developed on all projects and include an assessment of the project’s potential areas of vulnerability to modern slavery and human trafficking.
In order to encourage a safe space and open culture where all personnel feel able to report any concerns, Triple Line has a strict non-retaliation policy. We will not discharge, demote, suspend, harass, or in any manner discriminate against any person for making a good-faith report of ethics or compliance concerns. We have a zero-tolerance approach towards any such discrimination.
Plans for 2021
Training and awareness raising is Triple Line’s primary ambition for this year. As part of our review of all safeguarding principles we will be talking more openly and extensively with our personnel, partners, and team members about the risks around modern slavery and human trafficking.
We will continue to take a pragmatic and risk-based approach to our mitigation plans. We will continue to identify opportunities to eliminate modern slavery and trafficking within our supply chain and business operations. We will review our portfolio for the areas of greatest risk and where we have greatest opportunity to support and influence our partners to work more thoughtfully in this area.
Training on modern slavery and trafficking
Training is a key area of development for Triple Line in 2021. We are reviewing all our safeguarding policies and procedures and providing appropriate training for all. Modern slavery will form part of our review of our wider safeguarding commitments. This training will cover what the signs of modern slavery are, how to mitigate the risks of modern slavery, and how to report any modern slavery concerns on our overseas projects and in the UK. We also plan to give continued guidance to our bid teams on what to design into the delivery of our client’s programmes to mitigate against the risks related to modern slavery.
Approval of this statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Triple Line’s modern slavery and human trafficking statement for the year 1 January to 31 December 2021.
Mathis Primdal, Chief Operating Officer