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The Modern Slavery Act of 2015 ‘the Act’ requires certain businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains.
Designer Group M&E Services UK Limited ‘Designer Group’ is fully committed to playing its parts in eradicating modern slavery and to maintain and improve its systems and procedures to ensure that there is no complicity in human rights violations in its operations and those of its supply chain.
Designer Group recognises that slavery and human trafficking can occur in many forms. Therefore, throughout this statement the term “modern slavery” is intended to encompass all forms of coerced labour.
This statement refers to the financial year ending 31st January 2019. It sets out the steps taken by Designer Group to prevent modern slavery and human in its own operations and its supply chains.
2. COMPANY ORGANISATION AND STRUCTURE
The company is an industry leader in building services and provides a complete range of services including design, installation and maintenance to all sectors of industry and commerce. It is one of five companies comprising Designer Group Engineering Contractors Holdings DAC, which has its headquarters in Dublin, Ireland.
Designer Group M & E Services UK Limited has an annual turnover in excess of £36 million. Its operations fall within the United Kingdom.
3. OUR SUPPLY CHAIN
· Designer Group operates a number of policies that reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, customers and business relationships.
· Our supply chains provide materials and sub-contract labour to the company’s various projects. The company takes all possible steps to verify, evaluate and address risks of slavery and human trafficking in our supply chains. Responsibility for ensuring that this happens is held at Director level by the Board of Directors.
4. DUE DILIGENCE PROCESS
· In conducting appropriate due diligence, Designer Group assesses its suppliers across a number of key risk areas. There is an ongoing commitment to engage only those suppliers that uphold the same principles as Designer Group.
· The company’s verification process involves an assessment of our suppliers, who are required to complete a self-assessment questionnaire, including questions targeted at slavery and human trafficking risk.
· Designer Group uses this questionnaire to determine the risk profile of suppliers with regard to environmental factors, ethical trading and sustainable procurement, health and safety, quality, bribery and corruption, equality and diversity, slavery and human trafficking. The company engages in regular audits as part of the overall supply chain management process.
· Our suppliers are required to notify us of a breach of applicable laws or regulations and outline their practices and procedures to ensure they do not engage in modern slavery (including their own supply chain). This includes monitoring the content of modern slavery and human trafficking statements published by our suppliers and completing additional assurance activity when we visit our supplier sites.
· Wherever possible Designer Group employs its staff direct on permanent contracts, with direct terms and conditions that are considerably in excess of statutory minima.
· Designer Group encourages anyone, including its employees, sub-contractors, suppliers and clients, to report in good faith any issues or concerns about potential ethical, human rights, legal or regulatory violations. This approach is explicit in the company’s policies and procedures on Anti-Bullying and Harassment, Anti-Fraud, Bribery and Corruption, Equality and Diversity and in the company’s Whistle Blowing policy and procedure.
5. RISK ASSESSMENT
· As Designer Group is not in an industry with a high risk of modern day slavery, a risk based approach has been adopted to review supply chains that fall within industries that carry a high risk of modern day slavery.
· Starting with our own business operations and service providers together with our supply chains, we have worked to identify actual or potential risk of modern slavery.
· We review all our service providers annually to identify those with the highest potential risks of modern slavery. This is based in evolving risk in the sector, their contract type, the level of skill involved in the work, wages and our visibility of the service provider.
6. MEASURING EFFECTIVENESS
· We review the employment status and conditions of employment of all employees both in our own business operations and with providers of agency staff and temporary workers. This happens without exception upon supply or recruitment and regularly on at least an annual basis thereafter.
· In order to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, as well as other legal requirements we provide training to relevant employees as part of our overall briefing on the legal provisions and requirements relevant to our business.
· Our managers also receive further support that includes training and line management guidance to ensure consistency of our recruitment processes, management of suppliers, fair treatment at work, and inclusion and diversity.
8. BOARD OF DIRECTORS APPROVAL
· Responsibility for ensuring that the Group has appropriate policies in place to meet our obligations under the Modern Slavery Act rests with the Board of Directors.
· This Statement has been produced by the HR & Business Development Director and approved by the Board of Directors on 30th June 2019. It will be reviewed annually
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the company’s slavery and human trafficking statement for the current financial year.