RJ McLeod

Modern Slavery and Human Trafficking Policy

Modern Slavery Statement 2020

Introduction

This is the fourth Modern Slavery Statement prepared by RJ McLeod (Contractors) Limited. The statement is made pursuant to section 54(6) of the Modern Slavery Act 2015 for the trading year to 3 November 2019 and sets out the steps that we have taken and are continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or our supply chain. 

 

Business Activities

RJ McLeod operates in the civil engineering market working from offices in Glasgow and Dingwall. We are one of Scotland’s largest privately owned civil engineering companies, employing some 400 staff and operatives, the majority of whom are long-serving. This helps to enhance our reputation as an employer of standing. The average length of service for our staff is 15.0 years with the average length of service for our site operatives being 8.2 years.

Since our formation in 1951, we have 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 sub-contractors 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 sub-contractors for carrying out steel fixing and joinery works as well as complementing our own labour workforce.

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

 

Our Approach

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

We believe that everyone should have the opportunity to work. We comply with the applicable employment laws and our 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.

Our 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. We also expect a similar 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 our employees 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.  We are 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 and included in the 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 follows the procedures set out in the Working Rule Agreement (WR 22 Grievance Procedure and WR 23 Disciplinary Procedure).

In the main, suppliers and sub-contractors 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. Many of our supply chain members are of a size that means they are required to produce their own modern slavery statement.

If we use an organisation for the first time and it is not a recognised, established business then we undertake checks in respect of their practices. On occasion we use organisations outwith 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 major 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 and Standards

We operate a number of policies to ensure that we are conducting our business in an ethical and transparent manner. These documents can be found on our website:

 

  • Modern Slavery and Human Trafficking Statement

 

  • Anti-Bribery and Corruption Policy

 

  • Equal Opportunities Policy

 

  • Environmental and Sustainability Policy

 

Furthermore, we have supporting internal procedures including:

 

  • Corporate Social Responsibility Policy

 

  • Policy for Raising Matters of Concern

 

In line with Government requirements, our recruitment procedures require that all employees provide evidence of their eligibility to work in the UK.

As noted above, we have been an accredited Living Wage Employer since January 2018.

Additionally, we operate management systems accredited under the British Standards Institute. Within the control of these systems, our procurement processes define the procedures for the obtaining of goods and services from sub-contractors and suppliers.  

We expect our sub-contractors and suppliers to meet with the principles set out in this statement. To satisfy this commitment our terms of sub-contract have:

 

  • A Modern Slavery Clause. This clause explicitly states that any sub-contractor must ensure that no slavery or human trafficking takes place within their own business and in any part of its supply chain.

 

  • A Living Wage Clause. This clause requires that the real Living Wage is paid to employees of the sub-contractor, and its supply chain, when they are providing services to RJ McLeod.

 

Action Taken in Company Year 2018-2019

We are confident that there are no modern slavery or human trafficking practices within our business. It is impossible to guarantee that such practices are not present in our supply chain but what we can do is identify the risk. 

We believe that the risk of such practices being in our supply chain is low and can demonstrate this through the actions we have taken with our suppliers and sub-contractors and the training we have carried out with our staff, this being summarised as follows:

 

  • In the Company Year 2018-2019, we did not identify any human rights abuses and modern slavery in our operations or in the operations of our supply chain.

 

  • In the Company Year 2018-2019 our suppliers and sub-contractors, in the vast majority, came from the UK; our supply chain numbers being as follows:
    • Number of suppliers providing goods                 870 No.
    • Number of sub-contractors                                271 No.
    • Number of suppliers from outside UK                 Nil      
    • Number of sub-contractors from outside UK       1 No.
    • Number of suppliers from outside EU                 Nil
    • Number of sub-contractors from outside EU       Nil

 

  • We issued a questionnaire to a sample of our suppliers and sub-contractors. We asked 15 questions relating to the business and how it verifies its supply chain. 

 

  • The survey reflected 20% of our suppliers and 20% of our sub-contractors. The returns to the questionnaire were 75% for our suppliers and 75% for our sub-contractors. The responses showed that our supply chain complied with the Modern Slavery Act (2015). We chased up those organisations which had not responded and those who did subsequently reply confirmed compliance with the Act.

 

  • One of our clients asked us to complete a Modern Slavery and Human Trafficking questionnaire. We did this and were thereafter involved in follow-up discussions. The client involved was satisfied that we are conducting our business in an appropriate way.

 

  • In October 2019 we engaged an external training provider to conduct two full-day courses on “Understanding Modern Slavery and Human Trafficking for Commercial Organisations”. The course was given to key personnel involved in the procurement of goods and services and the control of construction sites.

 

  • Following on from the formal training, we also held internal workshops and discussions with relevant staff on how to recognise modern slavery practices.

 

Actions Proposed for Company Year 2019-2020

We intend to continue to increase our staff awareness of modern slavery practices and also look to further mitigate the risk of modern slavery practices occurring in our supply chain. The following actions will be taken:

 

  • As regards the training of our staff we will repeat the external one day course “Understanding Modern Slavery and Human Trafficking for Commercial Organisations”. This will be given to those key members of staff who had not participated previously.

 

  • We will continue with internal workshops with staff so that there is a fuller knowledge and understanding on how to recognise modern slavery.

 

  • We will provide guidance to site staff on what actions they should take if modern slavery practices are suspected.

 

  • A modern slavery toolbox talk will be prepared for delivery on our sites.

 

  • On those sites where a large number of sub-contractors are required, we will include reference to modern slavery in the site induction.

 

  • Modern slavery posters will be displayed in our site offices, messing facilities and safety rooms. Depending on the site and the number of sub-contractors involved, the posters may be in various languages.

 

  • We recognise the effects that the coronavirus covid-19 will have on the economic wellbeing of the UK and other countries – and those who live there – and hence we will remain vigilant to the fact that such economic conditions may be ripe for modern slavery practices to develop.

 

  • Our modern slavery questionnaire issued in 2019 will be further developed. It was the intention to issue this questionnaire again in 2020 but we recognise that “questionnaire fatigue” does exist and that to carry out such an exercise on an annual basis may diminish its effect. We will look to conduct the survey again in 2021.

 

  • We will develop a sub-contractor audit form for use on site. Our sub-contract documentation will be updated to make reference to such an audit.

 

Governance

This statement was approved by the RJ McLeod Board of Directors on 9 April 2020. 

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

 

BG CLARK
Joint Managing Director

Last Reviewed: 9th April 2020

 

RJ McLeod