MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2019
Our governance in relation to slavery and human trafficking
We have an established set of policies and procedures covering human rights in general and specifically addressing relevant areas to minimise the risk of slavery or human trafficking occurring in our businesses or supply chains.
Our relevant policies and procedures include:
• Our Ethical Business Practices Policy;
• Our Code of Conduct;
• Our People Policy – supplemented by our Recruitment Procedure;
• Our Procurement Policy – supplemented by our Supplier Code of Conduct; and
• Our Whistleblowing Procedure.
Code of conduct and ethical behaviour
Our Code of Conduct forms the cornerstone of our wider ethical business framework. It provides our people with the guidance and support necessary to carry out their work in the right way. We designed our code to help our people understand Thirdway Group’s core values and the responsible behaviours which underpin them. It provides guidance and support for all Thirdway Group personnel when undertaking their work and draws together all of our long-standing policies and procedures from all business areas into one simple and practical guide. We demand the highest levels of ethical and moral stewardship within the Thirdway Group. We are committed to being a responsible business and to developing mutually beneficial and sustainable relationships with our stakeholders and business partners, based on trust and co-operation.
Over and above the requirements of the Modern Slavery Act, we endorse the tenets of the United Nations Global Compact Principles, the International Labour Organisation Declaration on Fundamental Principles and the Rights at Work and the Ethical Trading Initiative ‘Base Code’. We strive to ensure that employment is chosen freely; freedom of association is respected; working conditions are safe and hygienic; child labour is not used; wages are not lower than minimum wage; working hours are not excessive; no discrimination is practised; regular employment is provided; and no harsh or inhumane treatment is allowed. We endeavour to carry out appropriate checks to ensure that any new applicant is suitable for the role that they have applied for. Prior to making an offer, it is our usual practice to ensure that all applicants are aware of what checks we will carry out. We make job offers subject to appropriate satisfactory vetting procedures (where required).
All our people undergo identity and Right to Work checks prior to commencing employment. We also carry out reference checking. We employ most of our people directly or on a fixed-term basis with checks in place to ensure that payment of salary is made direct to that person. Our Recruitment Procedure outlines the mandatory requirements we impose, which includes the requirement to use approved agencies in the recruitment process. Our Recruitment Procedure seeks to ensure that third-party providers can demonstrate that they comply with all legal requirements, including the requirement to comply with the Modern Slavery Act 2015.
Employee awareness and compliance
Our Employee Handbook and Code of Conduct set out our policies and key procedures. We give all our people access to the Handbook and a summary version of our Code of Conduct when they begin working for Thirdway Group. We also provide our line managers with a detailed copy of the Code of Conduct. These core documents, together with our targeted awareness on Modern Slavery and human trafficking helps us to deliver our key messaging so that our people can comply with our requirements. All these documents are available internally.
We expect our suppliers and other business partners to have the same high standards as we impose on our own business. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain. As part of our on-boarding process, our suppliers & subcontractors are required to read and acknowledge our Supplier Code of Conduct and our Supplier Guidance – Modern Slavery Act 2015 document. These documents set out key requirements for our suppliers including, amongst other things, the mitigation of risks associated with slavery and human trafficking. Our Standard Terms and Conditions require our suppliers to comply with all legal requirements, including adherence to the Modern Slavery Act.
Business and supply chain risk assessment and risk management
With the introduction of the Modern Slavery Act, we assessed our supply chain for potential areas of increased risk of non-compliance to the Act. We continue to do this and, where areas are identified, we carry out an audit, which will include a focus on compliance with employment as well as other regulatory and sustainability criteria. The defined criteria for assessing potential areas of risk within our supply chain are:
• Companies that operate using temporary low skilled labour;
• Operations outside of the UK / EU regulatory frameworks;
• Manufacturing or trading in raw materials produced in non-UK/EU areas;
• Companies that have a strategic partnership with Thirdway Group.
Our due diligence and audit processes in relation to slavery and human trafficking
We enforce our policies and procedures in an effort to ensure that slavery and human trafficking is not taking place anywhere in our business or supply chain. Our supplier on-boarding process includes standard due diligence procedures, which help us assess the suitability of a vendor to provide goods and services to Thirdway Group against compliance to required standards. This process captures confirmation that they are committed to ensuring that slavery and human trafficking is not taking
place within their own supply chain. Tender and supplier selection processes also include checks for acceptance of Thirdway Group terms and conditions and the Supplier Code of Conduct. Our procurement team carries out desktop audits as part of our supply chain management to provide assurance that our suppliers are responsible partners in our service delivery.
The effectiveness of our processes
We are using a number of key performance indicators (KPI’s) to measure how effective we have been in communicating awareness of our core policies and procedures related to the requirements of the Modern Slavery Act, and our other actions to seek to ensure that slavery and human trafficking is not taking place in any of our businesses or supply chains. The KPI’s used to measure against will be subject to ongoing review by the Board to ensure their continued effectiveness.
Training on slavery and human trafficking
We continue to strengthen employee awareness of our stance on slavery and human trafficking. We are updating our guidance for our suppliers, adding details of plans for managing the risk within our supply chain. This complements the training created for our own people, so they understand the issues involved, become more aware of the risks,
the signs to be vigilant of and how to raise awareness should they see or fear something suspicious. We believe that improved awareness is one of our most effective methods to reduce the risk of modern slavery and with the help of both our employees and suppliers we aim to ensure that there are no opportunities to hide forced labour within our organisation or our supply chain.
We encourage our people, customers and suppliers to report any concerns about unlawful conduct that they suspect is taking place at work. This includes any concerns regarding the risk of slavery or human trafficking. Our Whistleblowing Procedure provides our people and our business partners with the ability to report suspected wrongdoing. This Procedure enables concerns to be reported without fear of retaliation in the knowledge that we do not tolerate harassment, victimisation or reprisals against anyone raising a concern in good faith. In addition, employees who believe that they have come across an instance of modern slavery (or who may be a victim) and who need information and/or guidance on remedy, compensation and justice will be advised of their right to contact the Modern Slavery Helpline and/or other specialist support and assistance providers across the UK.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Thirdway Group Ltd’s slavery and human trafficking statement for the business period ending 30 September 2019 as approved by the Board of Directors.
Chief Operating Officer, Thirdway Group Ltd
01 October 2019
For and on behalf of the board of directors of ThirdWay ContractsLimited