Modern Slavery and Human Trafficking Statement
About our business and supply chains
Policies and due diligence
Code of Conduct
All of our suppliers and sub-contractors are required to follow our Code of Conduct and our Sustainable Procurement Policy specifies that suppliers must maintain their own ethical sourcing policies and apply these standards to their own business, across all of their workers, suppliers and any sub-contractors engaged in their supply chain. We seek to work with companies who share our principles and work according to our policies on health and safety, ethics, compliance and environment standards and who are prepared to commit themselves to meeting our requirements. We are committed to working with suppliers to support necessary improvements; however, we will also take action if suppliers and sub-contractors do not meet our standards. We review compliance by carrying out risk assessments, periodic reviews and comprehensive audits where there is a recognised higher risk.
Assessing the risk of modern slavery
We base our risk assessment process on the following criteria: potential for materials to come from high-risk countries; products and services using low skilled labour; reliance on temporary and transient labour; supply chain leverage; and the opportunity to do more.
Based on the criteria above we believe the business has a low overall risk of modern slavery in both our own operations and in our immediate supply chain. However, we are proactive in ensuring we are making our workforce, sub-contractors and suppliers aware of the potential risks, and are working to better understand the risks further down our supply chain.
Direct temporary and agency employment practices
Through our online recruitment system launched in 2019 (Eploy), we introduced a new agency portal, which has increased the visibility of agency labour providers, and plans are in place to audit our agencies quarterly. We are working to reduce the number of agencies on our system through a more robust tendering process and all will be signed up to a new Group contract with updated clauses to reflect policies.
We have informed all our sub-contractors of our requirements regarding modern slavery. We continue to provide information on the Act and its requirements on our commercial website which can be accessed here. Our risk assessment process undertaken by our divisional commercial teams identified three higher risk sub-contractor trades (security, landscaping and cleaning).
We invited these trades to attend sub-contractor breakfast briefings and to join the Supply Chain Sustainability School, (the ‘School’) in order to give them access to courses and training materials designed to help eliminate Modern Slavery and Forced Labour, which are available online.
Training and awareness
Key performance indicators
The development of our human rights framework will entail a wholesale review of our approach to broad human rights impacts including modern slavery. This will involve developing the necessary tools and capabilities for carrying out risk assessments and due diligence in relation to salient human rights issues and a means of monitoring performance through associated KPIs which will be published in our next statement.
Performance against KPIs is set out below. KPI
The number of Directors and Function Heads, Contracts Managers, Group Procurement Team and Group Commercial team trained on modern slavery through a tailored e-learning module.
431 out of 459 as of 25th September 2022