The Modern Slavery Act 2015 (‘the Act’) creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking. BuildEx is committed to supporting both the aims and the letter of the Act, namely to combat all forms of modern slavery and human trafficking and improve our practices across our group to help achieve this.
We have established rigorous HR processes, systems and controls to ensure:
All employees are assessed for their right to work in the UK
Workplace equality policies and practices are in place, promoted and implemented
Remuneration and benefit schemes comply with relevant UK employment legislation
We continually review and develop our policies, procedures, systems and controls to ensure ethical and legal compliance.
We actively encourage our employees to confidentially report any concerns or breaches e.g. suspected unethical behaviour and wrong-doing. We have an independent whistleblowing hotline to ensure that all of our employees have a voice that will be heard in confidence – 24 hours a day, every day of the year. All matters raised either via whistleblowing or through the auditing processes are investigated and appropriate action is taken in accordance with our policies and procedures.
Our Supply Chains
We purchase and source products primarily from countries within the EU, including the UK, but also globally on a much smaller scale. From the suppliers with whom we have direct purchasing relationships, we seek assurance during negotiations of the same high standards of corporate and ethical responsibility as we adhere to ourselves.
A proportion of our purchasing is through agents and intermediaries. Where this occurs, we recognise our ability to influence labour standards and human rights further back along supply chains is limited to a degree, as we may be only one of many international customers in an extensive global marketplace. Owing to these global suppliers, we recognise that some countries in our supply chain may present an increased risk of modern slavery.Accordingly, we are committed to investigating what more can be reasonably done in this regard to help our effectiveness at mitigating human trafficking and promoting anti-slavery within our supply chain.
Our timber purchasing complies with the EU Timber Regulation and we are Timber Trade Federation Responsible Purchasers, which requires continuing due diligence in our supply chains. We have held Forest Stewardship Council® (FSC®) and Programme for the Endorsement of Forest Certification™ (PEFC™) chain of custody for over a decade. These schemes address the rights of local and indigenous peoples in the countries where the producing certified forests are located. We are also highly active in promoting responsible purchase of certified wood and construction wood-based products in the market sectors we supply.
Identifying and MitIgating Risks
During the initial reporting period, we have identified that any potential risk of human trafficking and slavery, however remote, may occur in overseas supply chains beyond the EU and North America. To signal our intentions to our supply chain, we have, during the period, moved to a chain of custody basis for certain materials and products we purchase from these countries.
During the initial reporting period, we have also come to understand that we have much yet to learn regarding labour standards and human rights in the countries outside the EU and North America in our supply chain. We will be taking steps in the forthcoming financial year to increase our knowledge and understanding of labour standards in those countries, looking at implementing various measures to identify and mitigate risk and building on the approach deployed to ensure that we operate, as far as possible free from enforced labour, human trafficking and slavery.
Steps Taken: 2016 – 2019
Over the past two and a half years we have:
Brought our standpoint and responsibilities to the fore in our communications with all stakeholders
Developed and rolled out a specific Modern Slavery Act eLearning training module.
Distributed posters and flyers across the organisation’s premises outlining the Modern Slavery Act; what employees can do to flag up potential slavery or human trafficking; what external help is available, for example through the Modern Slavery helpline.
Developed an internal ‘Code of Conduct’.
Developed and published our own internal Anti-Slavery and Human Trafficking Policy (POL-BS-003)
Steps to Take: 2019 - 2021
In developing our response to, understanding and support of, the aims and requirements of the Act, going forward we will over the next 18 months:
Continue to bring our standpoint and responsibilities to the fore in our communications with all stakeholders
Establish a reporting cycle through our management team and board of directors, and ensure our employees receive ongoing relevant training
Improve and update our supplier contracts more specifically to exclude modern slavery and human trafficking
Develop a Purchasing ‘Code of Conduct’ that specifies supplier obligations and includes contractual compliances clauses and KPIs regarding modern slavery and human trafficking
Conduct on site audits (where appropriate, with qualified, independent 3rd party auditors) of our supply chain as appropriate and necessary to identify compliance gaps, validate human trafficking and slavery prevention practices and to build and improve the capability of those suppliers to avoid human trafficking and slavery issues
Implement any relevant emerging best practice, either specific and/or applicable to our industry sector, related to the aims and objectives of the Act
In adopting these steps, we believe this will help to develop our effectiveness at mitigating human trafficking and promoting anti-slavery.
This statement is made pursuant to section 54(1) of the Act and constitutes our Group’s slavery and trafficking statement for the financial year ending 31st March 2019.