Our business is committed to understanding modern slavery risks. This policy sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
2. ORGANISATIONAL STRUCTURE
Harry Fairclough Group Ltd had an annual turnover in excess of £36m for the year ending 31 March 2017. Harry Fairclough (Construction) Ltd is the main trading entity within the group.
3. SUPPLY CHAIN
The supply chain for our business includes subcontractors as well as providers of materials and equipment hire.
4. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Anti-slavery 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 anywhere in our supply chains.
5. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk –
- Our Code of Conduct Company Best Practice Guide (PM109) outlines the behaviours we expect form both employees and suppliers;
- We have detailed policies for the recruitment of both direct (PM017) and indirect (PM111) workers, as well as an Equal Opportunities and Diversity Policy (PM022);
- We directly employ and train our own workforce, supplementing this with operatives from our preferred agency supplier list as and when workload requires;
- We limit the geographical scope of our construction operations to the UK to ensure we are able to supervise all sites by appropriately trained and directly employed management teams;
- Where possible we build longstanding relationships with local subcontractors and suppliers and make clear our expectations of business behaviour;
- All subcontractors are required to pass a thorough approval process before being allowed to commence on any project;
- We expect all entities with which we contract directly to have suitable anti-slavery and human trafficking policies and processes. As it is not practical for us to have a direct relationship with all links in the supply chain, we expect each entity in the chain to apply due diligence on the next link in the chain;
- We have in place systems to educate, to encourage the reporting of concerns and to ensure the protection of whistle blowers.
6. SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and is signed on behalf of the Company by the Chairman and Managing Director of Harry Fairclough Group Limited.