RJ McLeod

Modern Slavery and Human Trafficking Policy

Modern Slavery Statement 2021

Introduction

This is fifth Modern Slavery Statement prepared by RJ McLeod (Contractors) Limited. The statement is made pursuant to section 54(6) of the Modern Slavery Act 2015. This document covers the trading year to 1 November 2020 and sets out the steps that we have taken and the planned way forward 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 12.6 years with 51.4% being with us for 10 years or more. The average length of service for our site operatives is 6.7 years and 40.0% have continuous service of 5 years or more. These length of service figures have reduced slightly as we have increased the number of new employees in the second half of 2020.

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 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 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 Joint 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 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. 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 trafficking 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 subcontractors and suppliers.

We expect our subcontractors and suppliers to meet with the principles set out in this statement. To satisfy this commitment our terms of subcontract have:

 

  • A Modern Slavery Clause. This clause explicitly states that any subcontractor must ensure that no slavery or human trafficking takes place within its 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 subcontractor, and its supply chain, when they are providing services to RJ McLeod.

 

Action Taken in Company Year 2019-2020

The biggest factor influencing our trading in the Company Year 2019-2020 was the coronavirus pandemic. Our construction operations were effectively closed from mid-March to June. Operations restarted on a measured basis with covid-19 protocols being instigated on sites and these protocols are not only continuing as of the date of this statement but also are expected to be in place for the foreseeable future. Notwithstanding the effect of covid-19, 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 subcontractors and the training we have carried out with our staff, this being summarised as follows:

 

  • In the Company Year 2019-2020, 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 2019-2020 our suppliers and subcontractors, in the vast majority, came from the UK; our supply chain numbers being as follows:
    • Number of suppliers providing goods                 1082 No.
    • Number of sub-contractors                                251 No.
    • Number of suppliers from outside UK                 6 No.     
    • Number of sub-contractors from outside UK       1 No.
    • Number of suppliers from outside EU                 Nil
    • Number of sub-contractors from outside EU       Nil

 

  • In October 2019 we engaged an external training provider to conduct two full-day courses in our Head Office 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. It was our intention to run the course to staff based in our North Office in the first quarter of 2020 but covid-19 meant that this was delayed until October 2020 when we again ran two full-day courses. Our key personnel who have the greatest potential for interface with modern slavery practices have now received formal training from a recognised training provider.

 

  • 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 and what to do if such practices are suspected.

 

  • In September 2020 we introduced a new Company Procedure – ‘CP6 Proactive Management against Modern Slavery’. This procedure sets out our management process and is distinct from the annual Modern Slavery Statement.

 

  • We have also produced a modern slavery toolbox talk (a brief PowerPoint presentation and video) and this was delivered to all sites week commencing 24 September 2020. Given that covid-19 restrictions were (and still are) in play, the talk was delivered in small discrete groups.

 

  • We have also introduced a ‘Modern Slavery Subcontractor Checklist’ (QD 159) and this is effectively used as an aide memoire by our site staff for reviewing subcontract operations/personnel. We are pleased to report that we have not had any concerns.

 

  • Modern slavery has also been part of the formal site induction on some projects, this being dependent on the size and nature of the works. Posters – including foreign language versions where appropriate – are also displayed in communal areas and welfare facilities.

 

  • One of our clients had previously 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 so impressed with our proactive approach to combatting against modern slavery practices that we were subsequently included as a case study in their own Modern Slavery Statement 2020 and also in their Corporate Sustainability Report.

 

Actions Proposed for Company Year 2020-2021

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:

 

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

 

  • Our modern slavery toolbox talk will be repeated on our sites.

 

  • On those sites where a large number of subcontractors 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 subcontractors involved, the posters will be in various languages where applicable.

 

  • We recognise the effects that coronavirus has had 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.

 

  • We will continue to use our Modern Slavery Subcontractor Checklist to review our subcontractors on site. Our Quality and Environmental Manager will keep a central record of such audits.

 

  • Our modern slavery questionnaire issued in 2019 will be further developed and we will look to conduct the survey again in 2021. We have recognised that ‘questionnaire fatigue’ does exist and hence we will ensure that the questionnaire is simple to complete but robust for the purposes of scrutiny.

 

  • We will look to investigate further the practices of our subcontractors and suppliers and particularly those who are not obliged to produce a Modern Slavery Statement.

 

Governance

This statement was approved by the RJ McLeod Board of Directors on 7 April 2021.

The statement is available on TISCreport.org and modern-slavery-registry.org.uk

 

BG CLARK
Joint Managing Director
Last Reviewed: 7th April 2021

 

RJ McLeod