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Modern Slavery Policy

Last updated: 15 January 2025

The Code of Conduct 

Our policy follows the set Code of Conduct for The Modern Slavery Act 2015. The provisions of the Code detailed below constitute minimum and not maximum standards, and shall not be used to prevent others from exceeding these standards. The Code, will be interpreted to comply with national and other applicable law. In the event that the Code exceeds the protections offered under the national or other applicable law, the provisions of the Code shall apply. 
The responsibility for communicating and enforcing the Code ultimately lies with the Peter Turvey, Director, but within the company each level of management will be responsible to ensure compliance within his or her own area within the business 

Employment:

  • All employees shall be free to choose their employment and shall not be forced to work against their will. 
  • Employees shall not be required to pay to work and must provide proof of eligibility to work. 
  • No original identity papers shall be retained by the employer. 
  • All employees shall be free to leave their employment after reasonable and/or contractual notice.

Working conditions and hours: 

  • A safe and hygienic working environment shall be provided and adequate steps shall be taken to prevent accidents and injury to health including the provision of regular health and safety training and appropriate personal protective equipment. 
  • Records shall be kept of accidents, injuries and known exposure to health and safety risks at work in accordance with relevant legislation. 
  • Accommodation, where provided, shall be clean, safe, and meet the basic needs of employees. 
  • Working hours shall comply with all national laws and any overtime will be voluntary wherever possible. 
  • Employees shall be given reasonable breaks while working and sufficient rest periods between shifts.

Pay: 

  • Pay and benefits shall meet, at a minimum, national legal standards. 
  • All employees shall be provided with written and understandable information about their employment conditions including pay within the required legal time frame and will receive a detailed pay slip for each relevant pay period. 

Child Labour: 

No child under the age of 16 shall be employed in a role that is likely to be hazardous or to interfere with the child’s or young person’s education or to be harmful to their health or physical, mental, spiritual, moral or social development. 

Equality and Respect: 

  • All candidates, employees, sub -contractors and agency workers will be treated equally and with respect, irrespective of age, gender, sexual orientation, religion, social background, disability race, union membership or political affiliation. 
  • The company will deal swiftly and appropriately with any incident which serves to discriminate, harass or intimidate any candidate, employee, sub-contractor or agency worker. 

  • Freedom of association: 
  • Employees, shall have the right to belong to, or join, a trade union of their own choosing. 
  • No employee shall be dismissed solely because of their affiliation to a trade union. 
  • Employee representatives shall not be discriminated against and shall have access to carry out their representative functions in the workplace. 

Reporting concerns: 

  • Everyone is encouraged to report suspected wrongdoing or poor practice as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate and that their confidentiality will be respected. 
  • Concerns should be raised initially to site managers who will speak with Project Managers either Mick Bacon or Keith Ware.  A meeting will then take place which will include the attendance of Gill Compton – Office Manager, Tracey Bell – Health & Safety Advisor and Peter Turvey, Director.

Non-Compliance: 

  • Anyone who fails to comply with the provisions set out in this policy, may be subject to disciplinary action which could result in their immediate suspension or the termination of their employment/contract. 
  • Failure to comply by agency workers will result in their actions being immediately reported to the agency and a request that they are replaced by another worker. 

    In relation to our suppliers and sub- contractors, we believe that transparency is vital to a successful business relationship. We are committed to building long-term relationships with suppliers and value open and honest communication with them. In the event of non-compliance, we expect our suppliers to be committed and engaged in remedying the issue within a time-frame set out in a corrective action plan to be agreed with the supplier and ourselves.