MODERN SLAVERY STATEMENT
Issue Date: June 2019
Next Review: April 2020
MODERN SLAVERY STATEMENT
Introduction
The Board of Directors are committed to preventing slavery and human trafficking within its business activities and supply chains assuring the effectiveness of any actions taken and future action planning and imposes the same high standards on its suppliers.
Organisational Scope
This statement covers the activities of Trant Holding Company Ltd:
Trant Holding Company Ltd is a family owned business that operates within the Construction and Engineering Industry. Trant Holding Company Ltd main business activities include civil, mechanical, process engineering and MEICA engineering, including full EPC services for private and public sector clients.
Trant Holding Company Ltd, key sectors include process & water, energy, oil & gas and nuclear. Trant Holding Company Ltd apply total engineering throughout the project lifecycle from design development through to commissioning and handover. Trant Holding Company Ltd provide their services for clients in the United Kingdom and internationally.
Trant Holding Company Ltd employs circa of 600 people, 250 of which are field based operatives.
To find out more about the nature of the business please click www.trant.co.uk
Countries of operation and supply
The Company currently operates in the following countries:
- England, Scotland and Wales.
- Falklands
- Singapore
- Channel Islands
In order to undertake its operations, the Company works with a range of suppliers including subcontractors, suppliers of materials and recruitment agencies.
The Company expectations and standards are communicated through the supply chain to set the standard of operation. It is the Company’s ethos to build strong relationships with the supply chain to understand their policies and compliance and assess the potential risks. The Company’s supplier approval process incorporates a review of controls undertaken by the supplier to assess compliance.
Policies
As part of the Company’s commitment to addressing and opposing modern slavery there is a range of policies to identify modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
- No Blame and Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or those of its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
- Employee code of conduct: The application of this policy provides clarity for employees regarding the behaviours that are expected of them and the actions that need to be taken when representing the Company. The Company expects employees to act with ethical understanding when interacting with the supply chain and operating overseas.
- Supplier/Procurement code of conduct: The Company is committed to working with suppliers to ensure the Company’s standards are mirrored throughout the supply chain. Suppliers are required to provide evidence that they act ethically, provide a safe working environment.
- Recruitment/Agency Workers Policy: The Company uses only agencies that are on the preferred supplier list to source labour and always confirms the working practices of any new agency it intends to use before accepting workers from that agency.
- Ethical Business Policy: The Company is committed to maintaining the highest standards of ethics and integrity and to conducting its business legally, honestly and fairly and requires all its employees to carry out their duties in accordance with these principles.
Our suppliers are made aware of the Policies and are required to adhere to the same standards.
Due Diligence
As part of the Company’s due diligence processes our supplier approval process is being developed to incorporate the following:
Undertaking risk analysis on the supply chain to assess product or geographical risks of modern slavery and human trafficking.
Assessing each new supplier for risk in accordance with this statement.
Conducting supplier audits and assessments to ensure compliance with the Company’s commitment to prevent modern slavery and human trafficking.
Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to report on how they intend to address the practices.
Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular, such as participation in "Stronger together" initiatives.
The procedures the Company is adopting have been designed to:
- Understand where there could be risk in the Company and the supply chain.
- Assess and review any risk in the Company and supply chain.
- Mitigate the risk of slavery and human trafficking.
- Give employees an avenue to raise concerns without the fear of reprisal.
Risk and Compliance
As part of the Construction and Engineering sector, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking as the industry has historically been found to be a highly targeted industry.
The Company assesses whether or not particular activities or countries are a high risk in relation to slavery or human trafficking by researching and assessing:
- The country in which the business operates specifically in countries where human rights are limited.
- In geographical regions in which the business operates where labour practices can be poor for migrant workers.
- On the supplier partnership risks.
High-risk activities
The following aspects are considered to be at high risk of slavery or human trafficking:
It is known that the construction industry and construction sites have been historically targeted by the trafficking regime and is considered to be of high risk to the Company operating within the said industry. The Company are committed to mitigating this risk through stringent identification checks of all staff directly employed by the Company, security clearance processes and complying with our contractual obligations for staff.
The Company also expect all recruitment agencies to follow Company policies and the Company only use approved reputable recruitment agencies. To ensure the potential for slavery and human trafficking is reduced as far as possible, the Company thoroughly check recruitment agencies before adding them to our list of approved agencies.
The Company also engages the services of subcontract labour both within the UK and internationally which is considered as high risk. The Company ensures that the supplier approval process is followed, and the Company applies its stringent subcontract assessment processes in compliance with pas91.
The Company has identified that supply of goods sourced from outside of the UK pose a high risk. To mitigate this the Company will check supply chains to ensure the potential for slavery and human trafficking is significantly reduced. The Company informs suppliers that we intend to engage with, that the Company is not prepared to accept any form of exploitation.
Performance indicators
The Company will instigate the following measures to monitor performance:
- requiring all staff to have completed training on modern slavery.
- implementing a system for supply chain verification whereby the company evaluates potential suppliers before they enter the supply chain.
- reviewing its existing supply chains, whereby the Company will evaluate all existing suppliers.
Training
The Company is committed to educating staff to recognise modern slavery and human trafficking in the Company and supply chains. The training programs will raise awareness, help to identify risk and encourage employees to report any breaches of this statement.
The Company's modern slavery training will cover:
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
- The Company’s purchasing processes in relation to the supply chain conditions.
- What external help is available through initiatives such as ‘stronger together’.
This statement is made in accordance with section 54 (1) of the Modern Slavery Act 2015 and constitutes the Trant Holding Company Ltd Modern Slavery statement, as approved by:
