Modern Slavery And Human Trafficking

Slavery and human trafficking is a heinous crime that affects communities and individuals across our global society.   We believe it is incumbent upon us as a Company to introduce these mechanisms in order to meet our obligations as a responsible supply chain partner.

We all have a responsibility to be alert to the risks, however small, in our business and that of our wider supply chain.   We expect our staff to report concerns and our management teams to act upon these.

Our organization structure

We are an independently owned civil engineering and utilities company organized broadly as follows:  Head Office functions, Civil Engineering, DrainsAid, Wales and Plant and Fleet.

Our supply chain

Our supply chain can be sub-divided into:

• Suppliers who we work with through our procurement processes and they supply us with goods and services from stationary and construction materials to heavy plant and equipment.
• Sub-contractors with whom we work in the delivery of our client contracts.

Our policy on Modern Slavery and Human Trafficking

We are committed to ensuring there is no slavery or human trafficking in any part of our business and we will work with our supply chain partners to ensure they adopt a similar approach.   Our 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 in any of our dealings.

Due diligence processes

We have identified the potential for risk within our business and put in place actions to address these as follows:

• We have standard recruitment procedures that apply in all recruitment activity
• And this includes the visible checking of documentation
• The geographical scope of our work activity is limited to ensure the appropriate level of supervision and management of our sites is maintained
• We have built long standing relationships with our suppliers and sub-contractors and have made clear our expectations of appropriate business behavior.  New suppliers and subcontractors are required to comply with our requirements in relation to our position on modern slavery and human trafficking
• With regard to national or in some instances international supply chains our point of contact is preferably with a local branch and we would expect these to have in place suitable anti-slavery and human trafficking policies and processes
• We have in place processes to encourage the reporting of concerns and the protection of whistle-blowers

Supply chain adherence to our values

We have zero tolerance of slavery and human trafficking and we expect all those in our supply chain – both suppliers and sub-contractors to comply with our values.

Directors are responsible for compliance in their respective departments and for their supplier and sub-contractor relationships.

Communication

We will  present our statement on our  website and  around our  premises to emphasize transparency and commitment in our  approach to slavery and human trafficking and we will  share  our  statement with  our supply  chain.

Internally we will  brief  our  workforce on this  commitment and encourage awareness and  the  action people  can take  if they  have  concerns.

Training

We will review our induction programme to ensure our commitment to anti-slavery and human trafficking is explained as well as the action an employee can take in the event of their concerns.

We will brief  our  managers on the  actions  we are putting in place  to address  slavery and human trafficking and make  clear  our  expectations of them in the  event of concerns being  raised.

Monitoring our effectiveness

We will determine appropriate key performance indicators to measure the effectiveness of our approach:

• Completion of audits of our supply chain partners
• Use of recruitment and payroll monitoring systems
• Regular supply chain reviews

This is made pursuant to Section 54(1) of the Modern Sla very Act 2015 and constitutes this Company’s slavery and human trafficking statement for the financial year 2016 -2017