Modern Slavery

Introduction

Hall & Riley Builders are a construction company carrying out works in the following sectors:
Education
Health
Housing
Commercial
Private

We have relationships with a large number of sub-contractors and, every day, a significant number of their employees will be working on our sites, in addition to our own employees. We also rely on a number of manufacturers, suppliers and distributors which, in turn, will source products from their respective supply chains.

Our policies
We have a number of policies that are designed to manage the risks relating to modern slavery and human trafficking issues, including our Employee Code of Conduct, Responsible Procurement Policy and Anti-slavery and Human Trafficking Policy. These set out our position of zero tolerance of modern slavery and human trafficking in any form in our business and supply chain. We are committed to acting ethically and with integrity in our business dealings and relationships and to maintaining systems and controls designed to ensure modern slavery and human trafficking are not taking place in our business or across our supply chain. Our Whistleblowing Policy provides a mechanism for our employees and others working in our supply chain to report suspected breaches of these policies.

We are aware that risks arising from modern slavery and human trafficking can apply anywhere in our operations, whether through direct employment, sub-contracted employees or the supply of materials. We expect our suppliers and subcontractors to ensure that there is no slavery or human trafficking in their supply chain. Where issues are identified (including through our audit process) that are not resolved to our satisfaction, we review the on-going nature of the relationship with that relevant organisation.

Our approach to assessing and managing risk
1. Our policy confirms our zero tolerance of modern slavery and human trafficking.
2. Our policies require that our sub-contractors and suppliers acknowledge their responsibility for adhering to our policies.
3. We have undertaken risk assessments to identify the key risks in our supply chain and review those risk assessments regularly.
4. We have issued minimum procurement standards for certain, high risk categories of materials and products. We keep these standards under review.
5. Our contractual terms include obligations on our sub-contractors and suppliers to comply with our policies, including our Anti-slavery and Human Trafficking Policy.
6. Our policies require our subcontractors and suppliers to complete an assessment to confirm that they comply with Hall & Riley Builders Ltd’s zero tolerance policy. During the year, we have worked with two accreditation companies in the UK (Chas, and Constructionline) to develop a set of common standards applicable to our sub-contractors and suppliers.
7. We undertake checks on new recruits to ensure that they are eligible to work in the relevant country of employment.
8. We continue to deliver training to key employees on the risks of modern slavery and human trafficking and our processes to mitigate these.
9. We continue to monitor the effectiveness of our actions against the risk of modern slavery and human trafficking. This includes reviewing our policies and our procurement standards and implementing an audit programme (see below).
10. We undertake audits of certain key supply chain partners to understand and validate the controls in their organisations and provide an opportunity to learn from best practice.

Next steps
We will continue to monitor the effectiveness of our actions against modern slavery and human trafficking. Next steps will include:
1. Continuing to develop further standards to support our Anti-slavery and Human Trafficking Policy (and related policies).
2. Keeping our pre-qualification standards for the appointment of new suppliers and subcontractors under review.
3. Continuing to train employees on identifying any potential issues within our operations and supply chain.
4. Updating the assessment of risks of modern slavery in our business and our supply chain.

This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015 and constitutes Hall & Riley Builders Ltd’s modern slavery and human trafficking statement for the financial year ending 30 June 2018. It was approved by Hall & Riley Builders Ltd’s board of directors on 18th December 2018.

 

Signed on behalf of the board of directors by: B A Maczka
Managing Director Hall & Riley Builders Ltd