RJ McLeod

Modern Slavery and Human Trafficking Policy

Introduction

This statement is made pursuant to section 54(6) of the Modern Slavery Act 2015, for the trading year to 28 October 2018, and sets out the steps that RJ McLeod (Contractors) Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within the business or supply chain.

RJ McLeod operates within the civil engineering market working from offices in Glasgow and Dingwall. It is one of Scotland’s largest privately owned construction companies employing some 400 staff and operatives, the great majority of whom are long-serving and this helping to further the company’s reputation as an employer of suitable standing.

Since its formation in 1951, RJ McLeod has been associated with a variety of civil engineering disciplines. Today our portfolio includes site infrastructure, public realm, both local and national road construction, energy, marine, waterways and land remediation and development.

We work solely in the UK and almost exclusively in Scotland. Being a civil engineering organisation our principal suppliers provide goods such as concrete, aggregates, pipes, reinforcing steel and the like and are similarly based in the UK. Our subcontractors also tend to be UK based companies and provide the construction disciplines which we do not do in-house such as piling, road surfacing, landscaping, electrical services, fencing etc. We also use labour-only subcontractors for carrying out steel fixing and joinery works as well as complementing our own labour workforce.

Over the years the Company has developed a tried and tested supply chain where mutual respect has been key to the success of the business.

Our Approach

RJ McLeod has a zero tolerance approach to any form of modern slavery and human trafficking in all its different forms and is committed to acting ethically and responsibly in its business relationships and to ensure that slavery and human trafficking are not present in any part of its business or in its supply chain.

We believe that everyone should have the opportunity to work. The Company complies with the applicable employment laws and its obligation is to ensure fairness in the hiring and advancement of all employees, both permanent and temporary, without discrimination. All of our staff have a personal responsibility for maintaining a respectful work atmosphere, free of abusive or unprofessional conduct. Every employee is expected to respect other people and treat them with dignity.

The Company’s commitment to respect in the workplace includes our full support for international efforts to promote ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. RJ McLeod also expect commitment to these principles from all organisations with which we do business and will not support or do business with any party knowingly involved in slavery or human trafficking.

All employees of RJ McLeod have a contract of employment. The contract sets out working conditions, hours of work, holiday entitlement and the like. Hourly paid site workers are engaged under a contract of employment which reflects the “Working Rule Agreement for the Construction Industry”, this being prepared by the Construction Industry Council – a body incorporating the employer organisations and trade unions. It is the properly recognised terms of employment for construction companies and is subject to annual review. The Company is also an accredited employer under the Living Wage Foundation meaning that employees are paid at a level at not less than the Living Wage, this being of relevance to the likes of cleaning and security personnel.

Additionally, all of our employees receive a “Starter Pack” on joining the Company and included in starter pack are our “Disciplinary and Grievance Documents”. These documents formally set out the processes to be followed when a grievance is raised or disciplinary action is required. The grievance and disciplinary procedure for our hourly paid workforce exactly follow the procedures set out in the Working Rule Agreement (WR 22 Grievance Procedure and WR 23 Disciplinary Procedure).

In the main, suppliers and subcontractors are established members of our supply chain and also recognised companies in the UK construction market and hence we have confidence in their meeting the obligations of the Modern Slavery Act 2015. If we use an organisation for the first time and it is not a recognised, established business then we would undertake checks in respect of their practices. On occasion we use organisations out-with the UK but from within the EU, principally companies based in the Republic of Ireland perhaps providing precast concrete products and the like. These are large majors companies and hence we have comfort that such entities are complying with EU modern slavery legislation.

Our operations mean that we have no direct contact with countries that are generally regarded as being the most likely to have a risk of modern slavery and human tracking as noted in the Global Slavery Index.

Policies

We operate a number of internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include an Anti-Bribery and Corruption Policy, an Equal Opportunities Policy. Furthermore, we have made commitments to Corporate Social Responsibility and in our recruitment procedures we have robust checks in place to ensure eligibility to work in the UK. Also, we operate an open door management system whereby employees are encouraged to raise matters of concern with senior management, this being formalised in our Policy for Raising Matters of Concern.

Additionally, the Company operates management systems, accredited under the British Standards Institute. Within the control of these systems, our procurement processes define the procedures for the obtaining goods and services from subcontractors and suppliers. We expect our subcontractors and suppliers to meet with the principles set out in this Statement and our terms of subcontract require such a commitment. Additionally, with our being an accredited Living Wage our terms of subcontract require a similar commitment from our supply chain.

Results from Company Year 2017-2018

In the Company Year 2017-2018, we did not identify any human rights abuses and modern slavery in our operations or in the operations of our supply chain.

Our supply chain numbers were as follows: • Number of suppliers providing goods 604 No. • Number of subcontractors 250 No. • Number of suppliers from outside UK 1 No. • Number of subcontractors from outside UK 1 No. • Number of suppliers from outside EU Nil • Number of subcontractors from outside EU Nil

Next Steps

RJ McLeod is not concerned about modern slavery practices within the Company. We are also confident that our supply chain meets the required standards too. Notwithstanding our confidence in our supply chain we recognise that we must remain vigilant and acknowledge that shortcomings may be possible in our supply chain. We will manage this risk by ensuring that we continue to work with suppliers from the UK and EU. Additionally, we will seek to confirm that our supply chain meets the requirements of this statement by carrying out an audit through a self-declared questionnaire. Furthermore, we will investigate the need for formal awareness training for our staff.

Governance

This statement was approved by the RJ McLeod Board of Directors on 5 April 2019.

The statement is available on TISCreport.org and modernslaveryregistry.org.

BG CLARK
Joint Managing Director

Last Reviewed: 5th April 2019

RJ McLeod