In 2015 the Modern Slavery Act become law. The Act consolidated and clarified existing legislation on slavery and human trafficking whilst increasing the maximum penalty for such offences. An Anti-Slavery Commissioner and new measures focused on supporting and protecting victims was introduced. Changes to Section 54 brought a requirement for commercial organisations with a turnover of more than £36million to produce an annual Transparency Statement. The purpose of the statement is to set out what an organisation has done to prevent modern slavery in their own business and supply chain. It is not a statement confirming there is no modern slavery anywhere in the business or supply chain.
Since The Act was introduced, we have formed a Modern Slavery Working Group, consisting of members of our Legal, Procurement, Human Resources and Sustainability departments, to work with our various business units and supply chain to try and tackle Modern Slavery. Whilst we are only required to produce a Transparency Statement by June 2017, we have already issued a position statement detailing our current stance on Modern Slavery. Click here
As a founding Partner of the Supply Chain Sustainability School we collaborated with other key companies within the construction sector to develop guidance for everyone to use around how to respond to The Act’s requirements. Following this, our own internal Working Group conducted a gap analysis on our current policies and procedures against this Supply Chain Sustainability School guidance. We found that whilst we already have a number of robust policies and procedures in place, there is scope to refine and improve upon what we have.
To help further improve our internal business processes, we have updated our recruitment policy and will be training relevant employees on what to look for, how to deal with a potential victim and provide awareness on what support is out there.
We understand that tackling Modern Slavery is a complex task. Whilst we are confident in the processes and procedures that we already have in place, however we are not complacent. Our initial priority will be to tackle the segments of our supply chain that may be vulnerable to human rights abuses, such as sub-contractors, overseas raw material suppliers and suppliers of goods that have long supply chains. Training and guidance will be provided, we will review their position on Modern Slavery within their own business and supply chain, and we will continue to run our Sustainable Procurement Initiative.
As part of the Sustainable Procurement Initiative all our active suppliers will receive a copy of our updated Supplier Code of Conduct. This document explains what we expect of our suppliers with regards to health & safety, labour standards, human rights, environment and bribery & corruption. Designated suppliers will be assessed in these areas by means of pre-qualification questionnaires, fact-finding and auditing. We will support suppliers to help them to develop and improve, however if they continue to fail to meet our standards, we will no longer work with them.
With the population growing, migration increasing, methods of organised crime ever evolving and supply chains becoming more complex, Modern Slavery needs to be a priority throughout industry and society. The journey all businesses are on to tackle the problem is complex, but through collaboration with our supply chain, customers, industry and supporting bodies we aim to make a difference.