Modern slavery
Modern slavery statement
We are committed, in accordance with our values and culture and as part of our wider approach to the protection and respect of human rights, to ensuring that slavery, servitude, forced or compulsory labour and human trafficking are not present in any form in the company, relationships with workforce or the workforce of direct and indirect suppliers and subcontractors. Read our full statement here.
Our supply chain
Our supply chain is diverse – the regional nature of our business means that there are more than 3,000 partners providing goods and services to our projects and offices across a very wide range of categories, with 99.8% of tier 1 suppliers being UK based (as of March 2024).
We have established a risk assessment process using a range of criteria to undertake the analysis. Due to the diverse and complex nature of the supply chain and due to the challenges with labour provision, we have identified the following as areas of risk:
- Supply chain category or trade. In the construction sector, contracts are often cost driven and this competitive environment can often reward lowest price. This may result in risk from exploitation of workers in certain trades. Recent supply chain disruption, the volatility of costs and labour supply shortages can all potentially contribute to increased risk through organisations attempting to remain competitive.
- Geography. Although our work is UK based and mostly UK sourced, there may be risk inherent in complex geographical supply chains. An example of this is the solar panel industry where we have taken significant steps to improve our due diligence practices.
- Labour provision. Where availability remains a challenge, we recognise that there is an ongoing skills shortage that has been exacerbated by the pandemic and changing immigration rules. Construction employs a wide range of skills but at lower and entry level, roles may be unskilled, and it may be a challenge to ensure that the documentary evidence demonstrating compliance and capability is in place for all workers. The rising cost of living may also compound worker vulnerability.
- Complex supply chain tiers. There can be limited visibility of the contracting party further down the supply chain, and subcontracts can often be further subcontracted. Given the range of roles within construction, there are many routes to securing employment including direct employment, temporary labour and indirect or subcontracted workers.
For those areas identified as high risk and complex, we will carry out a supply chain mapping exercise to map the supply chain to review and mitigate any risks identified both within our and our suppliers’ supply chains.
Labour provision
We have assessed our workforce requirements and due to our delivery model of subcontracting, there is not typically a requirement for the direct recruitment of trades where modern slavery may a risk. Our recruitment strategy has a huge focus on apprentices and graduates. The 2024 early careers recruitment campaign had 90 vacancies and, as usual, we have a high volume of applicants with c70% currently from within the UK.
We have recently become a member of The 5% Club and are committed to achieving 5% of our workforce in ‘earn and learn’ positions which includes apprentices, graduates and T Levels. In addition, as part of our social value obligations, we are committed to recruiting from our local communities which includes young persons no longer in the education system and who are not working or being trained for work.
Through our HR onboarding processes, we undertake right to work checks on new starters to ensure that they are eligible to work in the United Kingdom. In addition, we employ a third party vetting organisation to undertake BPSS checks which include identity checks, employment history checks, employment reference checks and basic criminal record checks.
We have fully implemented software which validates individuals’ relevant permits, accreditations and competencies of individuals working on site including providing clarity on individuals employers.
Where the requirement exists for recruitment of temporary white-collar staff, we have in place a small number of strategy partners. We have carried out full audits of these key labour providers to ensure compliance with all relevant legislation and with our modern slavery requirements. These audits are now planned to be carried out annually.
Please note: all of our recruitment routes are in line
with the Employer Pays Principle and commitments.