Modern slavery

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:

1. 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.
2. 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.
3. 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.
4. 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.

Supply chain audits

We have recently appointed a supply chain audit partner to carry out independent 3^rd party reviews of those trades, regions and subcontractors that we consider to be in the high-risk bracket. In considering who to appoint, experience in modern slavery risk mitigation in the construction industry was key and so we have partnered with an organisation who specialises in the industry, and which was set up by a former Deputy Director of the Gangmasters and Labour Abuse Authority with over 19 years’ experience investigating labour exploitation and modern slavery.

We have prioritised our supply chain audits based on the risk criteria outlined above, namely trade category and geography and have an audit programme in place for 2025.

Our supply chain audits are a blend of scheduled and non-scheduled site visits to our projects. We will also carry out agreed visits to supply chain partners to understand their approach to modern slavery and ensure they are doing everything they can to ensure that forced or compulsory labour and human trafficking are not present in any form in their organisation or its supply chain. This will include, where we believe the risk to be higher, a review of their sub-subcontracting arrangements and an understanding of how they are assessing and managing the risk further down the tiers of their own supply chain.

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 carried out annually.

Please note: all of our recruitment routes are in line with the Employer Pays Principle and commitments.

Fix-it

We have in place an anti-slavery and human rights policy which supports the UN Guiding principles on Business Human Rights, where we recognise our duty to respect human rights and provide access to remedy which includes supporting victims by referral to established victim-support mechanisms, engaging with local non-governmental organisations, industry bodies, trade unions or other support organisations and ensuring support and guidance for anyone affected.

Our approach to this can be found in our anti-slavery and human rights policy here.

Although we remain vigilant and committed to preventing and mitigating the risk of modern slavery, during 2024 we have not as yet had any whistleblowing notifications or potential risks raised.

Prevent-it

The Board of Directors of Tilbury Douglas Group has overall responsibility for oversight and implementation of our modern slavery policy, aimed at preventing and mitigating the risk of it occurring. Given that our project delivery is predominantly through our supply chain, our Procurement and Supply Chain Director takes the lead in the development and implementation of our modern slavery policies and following-up on any potential issues raised.

Management personnel, at all levels within each division and each business unit, are then responsible for promoting awareness of our approach, ensuring training is carried out and that all relevant persons under their control understand their obligations.

In the event of the discovery of any occurrence of modern slavery or human rights violation within our supply chain, we intend to adopt a range of measures, as appropriate to produce the safest outcome for the potential victims, to attempt to remedy the relevant situation and prevent further occurrences. These include reporting the incidence to the relevant authority and support for the victims, but also, we commit to providing support and guidance to allow third parties to make the necessary improvements to prevent recurrence.

We also have contractual mechanisms governing commercial relationships with our supply chain which may result in stop work notices, warning letters or supplementary training, and if continued breach or continued non-action is found, an appropriate exit strategy will be put in place.