G&D HIGGINS  MECHANICAL SERVICES  LTD

POLICY DOCUMENT NO 91

Modern  Slavery Statement

Overview

The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual

‘Slavery  and Human Trafficking  Statement’. The Statement must set out the steps an organisation has taken, if any,  during  its financial year to ensure that slavery or human trafficking is not taking place in  its supply chain.

Although  G&D Higgins does  not have this turnover, we still feel it is important to audit our behavior,  practices, suppliers  and train all our staff to be aware of this horrible practice.                                                                                                              ·

What is Modern Slavery?

Modern slavery  is an international crime,  affecting  an estimated  29.8 million  slaves around the world.  It is a growing global issue that transcends age,  gender and ethnicities.  It includes victims who have been brought from overseas and vulnerable people  in the UK, who are forced to illegally work against their will across  many different sectors  such as agriculture,  hospitality,  construction, retail and manufacturing policy.

The firm  is working  towards establishing a zero-tolerance position on violations  of anti-human trafficking and anti-modern slavery laws. If we find  breaches of these laws within our supply chain, we will  look to support  companies  in their efforts to   · comply with the legislation. We will not use these companies  if they cannot  change their practices.

Our CLEAR  values:  Collaboration,  Leadership,  Excellence,  Agility,  Respect,  and Responsibility will underpin  our culture and how we do business. :·They are    . embedded  throughout our business  and set the parameters, for how we expect people to behave with their colleagues, clients and the world at  large. We seek’ to treat everyone  fairly and consistently,  creating a workplace  and business environment that is open, transparent and trusted.  Our policies and procedures relating to the Modern  Slavery Act are in  line with our culture .and values.

Our structure and supply chains are in the UK only.

HOW WE CAN DO THIS

We have several procedures  in place that contribute to ensuring  modern slavery does not occur in our business or supply chains.

Employment:

  1. Robust recruitment processes in  line with UK employment laws, including:
  2. right to work’ document checks; contracts of employment and checks to ensure everyone employed  is 16 and above. An active and recognised  Apprenticeship Scheme.
  3. Market-related pay and reward, which is reviewed  annually-and linked to
  4. professional services firms’  benchmarks.
  5. An enhanced benefits package,  providing additional  health and welfare options to support  our people’s  (and their families) lifestyle choices.
  6. Transparency in our supply chains:

We recognise  our firm  is exposed  to greater risk when dealing with its suppliers, particularly  those who have operations/ suppliers  in other territories. The following measures to review and manage this risk are in place:

  • Examination of our supply chains  according  to location, size and industry, to identify potential  indicators of slavery.

Of these:-

  • 100% are located within the UK or other low risk countries.                                   .
  • 75% are companies with an annual turnover of> £36m, and are therefore covered  by The Modern Slavery Act
  • 11  % construction.

We have a commitment to collaborate  closely with suppliers, to help their understanding and work towards their own obligations  under the Modern Slavery Act.

G&D Higgins has a Responsible Purchasing Policy, which  reflects our commitment to and focus on suppliers’  ethical  supply chain(s).

A Supplier  Code of Conduct, which  is  used for all new major suppliers of goods or in re-tendering, clearly  stating the firm’s intention to step away (without penalty) if any occurrences of modern slavery are discovered.

Both the Responsible Purchasing Policy and Supplier  Code of Conduct will be, reviewed  annually  and updated  as and when deemed  appropriate by

G&D Higgins Mechanical Services Ltd to ensure they are continually developed  and remain fit for purpose.

Employee  training:                                                                   .

We want to help our people to understand  more about this growing issue and how to report any suspicions  they may have, whether  in a business. or in a personal context. We have highlighted the modernslavery.co.uk site to all our employees,  which holds useful information on how to recognise  different types of slavery,  how to spot the signs and provides details  of a telephone  helpline. We have developed resources and made them available to our people, including summary documents with an overview of the Modern Slavery Act, and links to the modernslavery.co.uk site.                                                                             ·

Reporting knowledge or suspicion of slavery:

We already have in place a whistle blowing hotline which ensures that anyone who has concerns, for example, about how partners or staff are behaving,  has a means of raising their concerns confidentially. Our hotline is now  also available to report any suspicions our employees may have regarding modern slavery and our employees have been signposted to this in our communications.

LOOKING FORWARD AND GOING FORWARD  will WILL AIM TO ORK TOWARDS:-

We will aim to develop an employee training module that will be undertaken by all employees. This training will outline what modern slavery is,  how to identify it and what individuals should do if they suspect there are any cases of slavery occurring. Completion of this training will form a compulsory part of our employees’ annual review and new starter induction processes and site inductions.                             ·

Developing a procedure to monitor how our suppliers comply with our supplier Code of Conduct.

LR Higgins Director of G&D Higgins shall take responsibility for this statement and its objectives which will be reviewed and updated as appropriate.

 

Linda Higgins

DIRECTOR

Reviewed 10/10/2019

 

A copy of this document can be downloaded here