Modern Slavery & Human Trafficking Statement

Read has a zero-tolerance approach to modern slavery.

At Read Construction, we recognise that slavery and human trafficking is significant human rights issue and are committed to taking appropriate and proportionate steps to mitigating the risk of these occurring within our business and our supply chain. We expect the same high standards from our supply chain partners.

This statement sets out to understand potential slavery risks related to its business and defines the steps in place to ensure that there is no slavery or human trafficking in our business and its supply chain. It outlines how we protect against modern slavery in our business and supply chains, to meet the requirements of the Modern Slavery Act (2015).

Organisations Structure:

Read is a regional SME main contractor. Read Construction Holdings Ltd is the main trading company of the Read group of companies. The group has approximately 70 employees across the North Wales and North-West England region and Read operates solely within the UK.

Our supply chains include in the region of 1221 suppliers, with circa 136 of these suppliers accounting for 80% of our expenditure on a regular basis. Our direct suppliers are almost all within the UK, and support our business in the provision of labour, plant, materials, equipment and professional services.

Our policies on slavery and human tracking:

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery 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.

Other supporting policies include or Ethical Trading Policy and Safeguarding Vulnerable Adults & Children Policy, as well as our Whistleblowing Policy allows any employee or third party to confidentially raise a concern and report suspected breaches of these policies.

We are committed to acting ethically and with integrity in all our business dealings, and to maintain & develop systems to ensure modern slavery and human trafficking is not taking place within our business or across our supply chain. Participating and promoting collaborative initiatives to raise awareness and prevent modern slavey, such as the Gangmasters & Labour Abuse Authority Construction Protocol or campaigns by Considerate Constructors Scheme.

Processes:

As a main contractor operating within the UK, the key areas of our operation that could be affected by slavery and human trafficking are our employees, agency workers working on our behalf, subcontractor operatives working on our sites, and the workforce of our supply chain who supply materials to our business. The steps that we take to mitigate risks in relation to each of these areas are as follows:

Employees:

Verify that all employees have the right to work in the UK upon commencement of their employment.
Provide all employees with a written Contract of Employment, and ensure they are fully aware of the terms of employment. Ensure all employees are issued the employee handbook and understand their rights.
Pay all employees at least the living wage.
Ensure regular training of the risk of modern slavery and human trafficking, good practice processes, how to assess the risk of slavery, how to identify slavery, how to report potential slavery issues internally or what external help is available.
Ensure all employees are aware of their own responsibilities in relation to preventing and reporting modern day slavery.

b) Agency workers

We only use reputable employment agencies to source labour, whose practices ensure all agency workers have the right to work in the UK, confirm that they do not charge workers a work finding fee and who have procedures in place to minimise the risk of recruiting forced or compulsory labour.
All workers to hold a value CSCS card (validated trade qualification).

c) Subcontractors:

Modern slavery compliance is an integral part of our supplier approval and re-qualification processes. Enforcing the requirements of the Modern Slavery Act via a Subcontractor Approval questionnaire, where all members of the approved supply chain to provide a declaration to confirm compliance with the Modern Slavery Act.
We ensure subcontractors confirm their employees have the right to work in the UK.
All new supply chain members a required to provide evidence of their own modern slavery policy / statement.
We consider sub-contractors’ approaches to employee rights and any breaches of human rights related legislation during our selection process.
We want all sub-contractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.
All subcontractors to hold a value CSCS card (validated trade qualification).

d) Suppliers:

We are committed to ensuring all suppliers adhere to the highest standard of ethics, by procuring the majority of our directly sourced materials from UK based organisations that are required to comply with UK laws on forced labour. Where materials are directly sourced from outside of the UK we consider the risk of slavery and human trafficking as part of our selection process.

Measurement – KPIs

We adopted the following KPI’s in 2023 to measure our effectiveness in assessing and managing the risk of modern slavery:

90% completion by all management / supervisory of regular Modern Slavery CPD – we achieved 100%
Carry out toolbox talks on the risks of modern slavery on all sites – Completed in 2023, and to be repeated on a regular basis (bi-annually).
Audit supply chain, labour agencies and security companies – targeted 5 audits (underway).

Process for reporting:

The business’ approach to the prevention of modern slavery has stakeholder buy in from the highest levels of management within our organisation. We are satisfied that we have in place systems to:

Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.
Protect whistle-blowers.
We have no reason for concern in relation to any current member of the supply chain and their compliance with the Modern Slavery Act.

Human Resources is responsible for the contents of this statement, which will be reviewed and updated as necessary on at least an annual basis. Overall accountability for compliance rests with the Executive Board.

This statement is fully supported by the Directors.

Dated: 9/04/2024

Signed: R. D. HEATON, MANAGING DIRECTOR