INTRODUCTION FROM THE MANAGING DIRECTOR
We are committed to improving our practices to combat slavery and human trafficking. George Leslie Ltd acknowledges its responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. As part of the company’s due diligence processes into slavery and human trafficking, the supplier approval process will include controls undertaken by the supplier to ensure compliance with the Act.
The company will not support or deal with any business knowingly involved in slavery or human trafficking. The company will immediately cease business with any supplier or any person acting on behalf of the supplier, which has committed an offence under the Modern Slavery Act 2015.
2.1 We provide civil engineering services across a variety of contruction and infrasture projects. We have over 200 employees and operate solely in the UK.
2.2 We have a global annual turnover of £50m.
3.1 George Leslie Ltd head office is based at; Blackbyres Road, Barrhead, Glasgow with construction sites operating only within the UK. Our supply chains include suppliers and subcontractors operating within the UK and have been given ‘Approved Supplier’ status by demonstrating legal compliance and risk control.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to taking all reasonable measures to prevent modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
5.1 As part of our initiative to identify and mitigate risk we apply appropriate due diligence when engaging with new employees, suppliers and sub-contractors, which is informed by the nature of procurement and services to be delivered.
5.2 All new employees are subject to ‘right to work in the UK’ checks on commencement of their employment. Working hours and leave entitlements are communicated to the employee via the staff hand book and terms of employment. All employees are encouraged to raise any modern slavery concerns they may have within the company or supply chains with the HR Manager or Director.
Any concerns raised will be treated in line with the Company Whistleblowing policy.
5.3 All suppliers must satisfy our ‘approved supplier’ prequalification checks which includes declaration of their compliance with Modern Slavery legislation. Prevention, detection and reporting of modern slavery throughout GL and supply chains is the responsibility of all working across the organisation.
5.4 GL has assessed the risk of human trafficking in our supply chain as extremely low, based on 99.5% of our suppliers being UK based and every supplier’s commitment to compliance with the Modern Slavery Act 2015, prior to acceptance on our approved tenderers list.
5.5 We have in place systems to:
(a) Identify and assess potential risk areas in our supply chains
(b) Eliminate the risk of slavery and human trafficking occurring in our supply chains
(c) Monitor potential risk areas in our supply chains
(d) Protect whistle blowers
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
6.1 We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics we have in place a supply chain compliance programme. Our suppliers are required to re-apply for their ‘approved supplier’ status every three years.
Further checks such as on-site inspections / audits will be carried out where Senior Management identify any high risk and critical suppliers.
6.2 We have a dedicated compliance team, which consists of involvement from the following departments:
(b) Audit and compliance
(c) Human resources
7.1 To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff and display awareness posters on our sites.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
8.1 We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
8.2 Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:
(a) Introduce a modern slavery awareness section within company Health and Safety workshops
(b) Introduce a formal risk assessment to identify potential areas of risk within the business.
(c) Develop an appropriate audit procedure to reflect the level of risk.
8.3 This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending March 2022.