Ashe will work to promote awareness amongst its employees of modern slavery and human trafficking within the UK construction industry. The company will ensure that their employee pay and conditions remain at a high standard, above those dictated by the Act. Any potential contravention will be dealt with seriously and investigated appropriately by the directors, as will any recommendations for improvement within the business. Any whistleblowing or complaint by an employee will be supported and investigated through our formal grievance procedure.
The directors believe that the risk of failing to comply with the Modern Slavery Act 2015 is low, because of the following measures:
- All employees are on full written conditions of employment that are standardised and checked for compliance with the Act.
- All employees are paid at or above the “Living Wage”.
- No casual labour is employed.
- Unpaid work experience or internships are regulated through a standardised risk assessment and are time limited to one week.
- Appropriate training of relevant staff is carried out on a regular basis.
Within our subcontractor supply chain
Ashe will work to prevent modern slavery and human trafficking within our sub-contractor supply chains through reducing the risks and working to influence behaviours within our directly contracted sub-contractor organisations. Any failure to address these issues that results in a contravention of the Act, a possible contravention, or a perceived contravention of the Act that could impact the reputation of Ashe may be investigated and result in a variety of actions, up to and including removal from our supply chain.
Within the current financial year Ashe will undertake the following activities:
- A review and amendment of standard terms of engagement to incorporate the requirements of the Act and requirements of Ashe.
- Each order will remind subcontractors of their responsibilities to their supply chains and the implications to working with Ashe. It will also provide for a reporting structure for any infringement or potential infringement.
- Large companies caught by the Act will be expected to provide their slavery and human trafficking statements for our records and review.
The Construction and Operations Directors at Ashe are responsible for compliance with these requirements.
Due diligence processes relating to slavery and human trafficking
As part of our efforts to monitor, manage and reduce the risk of slavery and human trafficking occurring within our business or supply chains, our processes aim to:
- Identify, monitor and manage areas of potential risk in our business and supply chains.
- Scrutinise any identified areas of risk within our business and supply chains.
Adopt a zero tolerance approach to slavery and human trafficking throughout the organisation and our supply chains.
Provide support and protection from detriment or disadvantage to any person who, in the public interest, raises genuine concerns amounting to a protected disclosure.
Risk and compliance
Within the current financial year we will consider any key risks that might lead to a potential contravention of the Act within our own businesses and our supply chain. Should any new areas of concern arise we will seek to introduce mitigating acts to manage these new threats as effectively as possible. Part of this process may include a risk assessment in respect of an emerging risk which would be carried out in conjunction with our leadership team, including members of procurement and production, as well as our supply chain.
A risk assessment may consider the most appropriate form of whistleblowing to ensure that this is condoned and a useful way of ensuring compliance.
Success and effectiveness of our policies and processes
The directors may determine an appropriate set of benchmarks to ensure that slavery and human trafficking is not taking place in their businesses or supply chains and that, where there is an indication that there is a risk, it is investigated and managed. It is anticipated that this may require key performance indicators. All investigations will be carried out appropriately.
We ensure all employees are aware of the risks of modern slavery and human trafficking in our business and supply chains. Detailed below are examples of the training programmes we have in place to enable our employees to identify and report any potential breaches of the organisation’s anti-slavery and human trafficking policies.
- Company policy, procedures and best practice guides are available on our company network.
- Discussions at our Departmental Meetings.
- Training has been provided to all employees on the Act, its requirements and the support available. This training is repeated every three years.
Further actions, approval and endorsement
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, the following steps are examples of how we are tackling slavery and human trafficking:
- Introduction or review of new policies or procedures.
- Consider appointing an independent body to carry out an annual audit of our business and supply chains to monitor how successful we have been in keeping slavery and human trafficking at bay.
- Modern Slavery Briefing notices to be displayed on our construction sites including the signs to spot potential victims.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Ashe’s slavery and human trafficking statement for the financial year ending 31st December 2023.
Group Chief Executive August 2023