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Modern Slavery and Human Trafficking Statement and Policy

This Ground Construction Limited (GCL) Slavery and Human Trafficking Statement (Statement) is made pursuant to the Modern Slavery Act 2015 and relates to the financial year 2024-2025. This Statement covers the activities of GCL. It sets out the steps GCL  has taken prior to, or will take during, the Financial Year to ensure that slavery and human trafficking is not taking place in either any of GCL ’s supply chains or in any part of GCL ‘s business.

GCL’s organizational structure, business and supply chains

GCL is a privately owned company who has built a reputation as one of the premier ground works and RC concrete frame contractors in London and the home counties of England. GCL supply chain is primarily comprised of organizations within the UK or Europe. GCL Activities are primarily undertaken in the United Kingdom. GCL UK does not normally operate directly outside UK.

GCL’s Policy in relation to slavery and human trafficking

GCL does not permit, condone or otherwise accept any form of slavery and/or human trafficking (as defined in the Modern Slavery Act 2015) either by its employees, subcontractors, contractors, agents, partners or any other organization, entity, body, business or individual with whom GCL engages or does business. GCL is committed to preventing any form of slavery and/or human trafficking in its activities and to ensure that its Associated Parties are free from any form of slavery and/or human trafficking. In the event that GCL suspects any slavery and human trafficking by an Associated Party, GCL reserves the right to: report such suspicions, provide appropriate information to the relevant authorities, and to suspend or terminate any associated engagement, business arrangement or contract. Each Associated Party is required to: put in place suitable management policies / system(s) for ensuring compliance with the Policy; extend the principles set out in this

Policy to those engaged or acting on the Associated Party’s behalf, including contractors; and to permit GCL to audit its compliance with the Policy, including making records available to GCL to demonstrate compliance with the Policy.

GCL’s due diligence processes in relation to slavery and human trafficking in its business and supply chains

To ensure that no slavery or human trafficking is taking place within its supply chain, GCL shall;

  • Incorporate the Policy into GCL’s Business Conduct Principles for suppliers, subcontractors and partners.
  • Publish the Policy on the GCL internal staff portal & website for public access.
  • Publish the Business Conduct Principles on the GCL website for reference.
  • Incorporate the Business Conduct Principles and thereby the Policy into the GCL Purchasing Terms.
  • Include an acceptance condition in the GCL supplier pre-approval questionnaire that suppliers will abide by the Policy.

The Parts of GCL business at Risk

There may be a risk of slavery and/or human trafficking through organizations with whom GCL contracts for the supply of products or services, or through organizations with whom GCL subcontracts work to or partners with. The appointment of suppliers and subcontractors is subject to careful due diligence to ensure that there is no perceivable risk of slavery and/or human trafficking. GCL engages only with reputable suppliers or parties that do not engage in any form of slavery and/or human trafficking. All such parties are also expected to adhere to GCL Business Conduct Principles, which is incorporated into the process for being appointed as such and/or the relevant contractual relationship.  GCL avoids contracting with suppliers or subcontractors which are located within geographical areas where slavery and/or human trafficking are a risk. In the event that GCL contracts with Suppliers or subcontractors outside of the United Kingdom, it shall assess the supplier/subcontractor and the relevant geographic area on a case-by-case basis, undertaking any necessary due diligence in accordance with the paragraph below.  The GCL Management shall be responsible for any compliance matters set out in this Statement and Policy, for ensuring due diligence and for undertaking audits. The GCL HR Team is responsible for ownership of this Statement and Policy, including ensuring that it is up-to-date.

GCL’s Effectiveness & Measures

The effectiveness of ensuring that slavery and human trafficking is not taking place in GCL’s business or supply chains shall be assessed by application of the following key performance indicators;

  • To raise awareness of slavery and human trafficking by bringing the contents of the Statement and Policy to the attention of all staff, by publishing it under Company Policies on the internal portal and providing a formal notice to it.
  • Require staff that induct new employees to introduce employees to the Statement and Policy. (Date required: ongoing throughout the year.)
  • Incorporate supplier adherence to the GCL Policy and the Business Conduct Principles within GCL’s supplier appointment process. (Date required: within 28 days of Statement / Policy adoption, ongoing throughout the year.)
  • Review all existing supply chains. (Date required: within 3 months of Statement / Policy adoption, ongoing throughout the year.)

GCL can provide awareness training about anti-slavery and human trafficking to its staff

  • Visibility of the statement and policy on internal staff portal.
  • Communication to staff to read the Statement and Policy.
  • Annual reminder to ensure that staff is familiar with the Statement and Policy.
  • New staff to be introduced to slavery and human trafficking policy as part of their induction.

This statement has been approved by the GCL board of directors.

Mr Trevor Diviney
Position: Executive Chairman
Date: 9th July 2024