MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

 

Introductory Statement from Director 

ModernSlaveryandhumantraffickingcantakevariousformsincludingslavery,servitude, forcedand compulsorylabour,allofwhichhaveincommonthedeprivationofaperson’slibertyfor personalor commercial gain. Wemaintainazero-toleranceapproachtothesepractices, andwe remaincommitted to acting ethically,transparently andwith high integrity inallour business dealings and relationships. 

We expect the same high standards from all our contractors, suppliers and other business associates andweexpectthemtoholdthebusinesseswithintheirownsupplychainstothesamehigh standards. 

Our Supply Chain 

It is widely acknowledged that the construction industry is a high-risk sector for modern slavery and  human trafficking, largely due to the demographics of the temporary labour workforce and complex  supply chains. 

We aim to ensure that we only work with credible suppliers and contractors so as to limit the  potential risk of slavery or human trafficking in our business and supply chain.  

Practices 

We pay allofourdirectly employedworkers atleastthe statutoryUKNationalMinimumWageorthe UK National LivingWage (as applicable to the age ofthe worker). 

We take steps to ensure that all our workers are eligible to work in the UK, either as part of our own  recruitment process for directly employed workers or via our agency suppliers’ processes. We also carry out DBS (Disclosure and Barring Service) checks and PVG (Protecting Vulnerable Groups) checks where statutorily required. 

Temporary Workforce 

Our temporary site-based workforce is particularly vulnerable to the risk of modern slavery. We  continue to be proactive in mitigating this risk by outsourcing the recruitment process of this  workforce througha reputable third-partycompany. All agency suppliers are required to agree to comply withtheActandtogivevariousassurancesthattheirpersonnelandtemporaryworkersare not victims of  slavery or trafficking. Agency suppliers are also required to complete an annual questionnairerelating toobligationsundertheActsothatanyinadequaciescanbeidentifiedand addressed. 

To furtherstrengthen the assurances detailed above,we require the outsourcingpartnerto undertake audits onourlaboursupplierstoensurethatthey also complywiththeActandpay ourworkers no less than the statutoryUKNationalMinimumWageortheUKNational LivingWage (as applicableto the ageoftheworker) and thatthese pay rates are not reduced by the treatment oftravel and/or subsistence expenses. These auditsmay take the formof an on-site orremote review ofthe records held by each laboursupplier, including sight of workers’ payslips,rightto work documents and terms of engagement. 

Adherence to our values and policies 

We expect our employees (whether permanent, fixed term or temporary), directors, casual and 

seconded staff, consultants, suppliers and subcontractors to share our own ethics and values by  complying with our Anti-Slavery and Human Trafficking Policy, Money Laundering and Terrorist  Financing PreventionPolicy, andourAnti-Bribery andCorruptionandFraudPolicy. We require suppliers and subcontractors to agree to representations and warranties contained in our standard Terms and  Conditions, Subcontract Agreements and Framework Agreements relating to the prevention and 

detection of modern slavery and human trafficking. In addition, we require them to implement due diligence procedures within their own supply chains. 

Whistleblowing 

Inordertodetect,reportandultimatelypreventmodernslaveryinanypartofourbusinessorsupply chain wemustencouragethoseworkingwith,orforus,toraiseanyconcernsorsuspicionsatthe earliestpossible stage and without fear of detrimental treatment. To achieve this, employees as well as new suppliers/subcontractors are given guidance on our Whistleblowing Procedure and have access to an external and anonymous‘whistleblowing hotline’. 

Grievances or Complaints Received 

Therewere no grievances or complaintsrelated tomodern slavery or human trafficking during the financial year end 31 August 2018. 

Training and Awareness 

We have introduced an eBook “Whatis Modern Slavery?” which is mandatory for all existing and future employees, consultants, and temporary non-site-based workers of the Group. We believe that by completing thistrainingemployeeswillgainawiderknowledgeofmodernslaveryand humantraffickingandenablethem torecognisepotentialareasofriskwithintheworkplace. Wewill alsobeintroducinganeLearningmodule tailored for key employees designed to provide a deeper understanding of modern slavery and human  trafficking. Completion of the eLearning modules will be measured as a KPI within the forthcoming financial year. 

Future Steps 

We aim to align our policies and procedures onmodern slavery and human trafficking with best practice andchangesinlegislation. To that end,we aimto take the followingsteps during the financial year ending 31 October 2019: 

Training Supply Chain 

Weaimtointroducetraining specificallyforthoseemployeeswhohavetheabilitywithintheirjob role to identifymodern slavery within oursupply chain. 

Awareness 

Inorderto increase awareness acrossourbusiness,wewill publisharticlesonmodernslaverywithin staff and  homeownerpublications. 

Site Labour 

Werecognisethat victimsofmodernslaverywithintheconstructionanddomestic servicessectorare oftenEU migrant workers. An analysis of ourtemporary labour workforce is being undertaken in light ofthepotential impactofBrexit. Thiswillalsogiveustheabilitytogreaterassessthepotentialrisk onmodern slavery and take proactive action. 

Key Performance Indicators 

Our KPIs will develop over time and our initial key measures are:

Measuring the numberofsuppliers and contractors who have received a copy ofourmodern slaverypolicy, grievances/complaintsreceived,andriskassessmentsundertaken. 

We reviewourAnti-Slavery andHumanTraffickingPolicy andotherrelated policies onannual basis.