Modern Slavery and Human Trafficking Policy

This statement has been produced in accordance with Section 54(1) of the Modern Slavery Act 2015. It states the actions the Group has taken during the financial year ending 31 March 2020 to ensure modern slavery and human trafficking is not taking place in its operations and supply chain.

OUR BUSINESS AND SUPPLY CHAIN
Gratte Brothers Group is a family owned building services company providing from one source a complete range of electrical, mechanical, security and commercial catering facility services. The Group is comprised of Gratte Brothers Limited, Gratte Brothers Specialist Services Limited, Gratte Brothers Security Management Limited, Gratte Brothers Catering Equipment Limited and Gratte Brothers Technical Services Limited.

The Group operates from head office (London) and 5 branch offices (Belfast, Chelmsford, Stevenage, Warrington and Worthing) as well as multiple sites across the United Kingdom and Ireland. The Group turnover exceeds the £36 million threshold for this financial year.

The company’s supply chain is made up of material and plant suppliers, professional service providers, recruitment and labour agencies and trade sub-contractors.

The company’s labour force consists of permanent employees, agency workers and trade sub-contractors. The company is a registered member of the JIB (Electrical), BESA (Mechanical) and JIB PMES (Plumbing) organisations and complies with and ensures that labour supply agencies and labour only sub-contractors comply with the
National Working Agreements. The company also works with the Unite Union on labour relations.

POLICY
The company has a zero tolerance approach to all forms of modern slavery and human trafficking within its business and supply chain and is committed to acting ethically and with integrity in all business dealings. This is supported by our Ethical and Sustainable Procurement Policy.

Where staff have concerns around issues of forced labour, human rights, recruitment practices or exploitations, they are encouraged to report these concerns to management or alternatively staff can contact the free 24 hour confidential Employee Assistance Programme helpline 0800 350 5182 offered by Health Assured.

Upon a claim of believed slavery and/or human trafficking being disclosed, the company will investigate the allegation and in the event of it being proven, will notify the relevant authorities while, as far as is practicable, providing support to the victim(s).

DUE DILIGENCE
Supply Chain
As part of the company’s supply chain approval process for new trade contractors/suppliers, a pre-qualification questionnaire is issued where aspects of social and ethical values, including slavery and human trafficking, are examined. The completion of this questionnaire allows the company to identify potential risk areas within the supply chain. For existing trade contractor/suppliers a 2 year re-approval process is in place.

Scheduled 2nd party supplier audits take place, along with regular individual engagement meetings with supply chain members.

Recruitment
The Human Resources department has in place a preferred supplier list (PSL) of agencies offering labour supply and recruitment services which is reviewed on an annual basis. The company carries out compliance audits of recruitment agency practices covering organisational structure, accreditations, right to work checks, modern slavery, anti-corruption, minimum wage, wage calculations, occupational health and pension arrangements.

RISK ASSESSMENT
The company has mapped out our supply chain of goods and services to identify elements of works and materials/products that are derived from outside the UK and Western Europe, especially high risk countries as detailed within the Modern Slavery Index, and is concentrating on these suppliers first, as they represent the highest level of risk to the company.

Members of our HR, Procurement and Operations departments have received specialist training on preventing and tackling modern slavery to identify where potential high risk companies may be engaged. This training was delivered by Stronger Together (www.stronger2gether.org) and raises awareness of how to spot
signs of modern slavery and how to approach modern slavery in supply chains.

A Group Risk Director has also been appointed to oversee and manage the level of risk exposure to the company.

PROGRESS TO DATE
In 2017/18 the company registered and completed a self-assessment using the Supplier Ethical Data Exchange (SEDEX) to identify and mitigate the risks of slavery and human trafficking. This tool assesses the company against a number of categories including labour standards, health and safety, environmental and
business ethics.

Since the implementation of the Modern Slavery statement a number of staff from across the business have undertaken training relating to Modern Slavery. This included staff from operational activities as well as relevant Group support functions with influence on the supply chain and labour throughout the business.

Modern Slavery questions were added to the company’s audit matrix checklist for supply chain members and an audit programme was introduced to include second party audits of our Tier 1 trade contractors and PSL labour supply agencies.

Progress in 2020 was slow due to the COVID-19 pandemic with works on improving the reporting mechanisms and supply chain mapping undertaken. We have carried out risk assessments on contractors based on their size, nature of work and amount of work carried out for Gratte Brothers, which will be used to identify key audit
targets in the coming year.

FUTURE PLANS
The company will review our supply chain audit programme to increase the number of audits carried out, the scope of the audit checklist and to include recruitment agencies, manufacturers and service providers.

The company will develop and introduce in-house modern slavery awareness tool box talks covering illegal working, slavery and forced labour. Initially, this will be delivered to our site teams including our supply chain subcontractors as this is where the potential to witness modern slavery is greatest.

The supply chain department has delegated the approval process to an external verification specialist and appointed Achilles to undertake these assessments, where possible, in the future.

An internal point of contact will be established with the Group for staff to raise concerns they have have around potential exploitation or modern slavery on site. This point of contact will be independent from the HR and Supply Chain departments to avoid conflicts of interest. It will be possible to report this through an email address or a phone line which will be diverted to the point of contact. All contact will be kept confidential and the person reporting their suspicions will have their anonymity protected.

An updated whistle-blowing policy including guidance on how to report concerns regarding modern slavery will be developed and implemented.

AWARENESS ACROSS THE BUSINESS
As part of a review of the company’s induction process for new staff members, the HR induction has been redesigned to include awareness of the company’s commitment to ensure that modern slavery is not taking place within its operations and supply chain, including what steps are being taken and guidance on identifying risk areas in regard to slavery and human trafficking. Guidance will be given to existing staff members and suppliers through toolbox talks and refresher training as necessary.

This statement has been approved by the Gratte Brothers Group Board and applies to all companies within the Group.

D Gratte

Group Director

20 November 2020

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