Anti-slavery and human trafficking Policy Statement
Introduction
This policy applies to all persons working for Woodhart Construction Limited or on our behalf in any capacity, including employees at all levels, directors, managing officers, agency workers, sub-contractors, and suppliers.
Woodhart Construction Limited prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect our suppliers will hold their own suppliers/supply chain to the same high standards.
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
Commitments
We shall be a company that expects everyone collaborating with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
The prevention, detection, and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
We are committed to engaging with our staff, sub-contractors, and suppliers to address the risk of modern slavery in our operations and supply chain.
We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
Consistent with our risk-based approach we may require employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us conducting audits of suppliers for their compliance with our Code of Conduct.
If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take immediate and appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
Anti-Bribery Policy
Introduction
Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us, and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by employees or by third parties acting for or on behalf of the Company.
Policy
It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
Suspicion
If we suspect that you have committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.
Reporting
If you, as an employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to a director. You may be asked to give a written account of events.
Staff are reminded of the Company’s Whistleblowing Policy which is available in this Employee Handbook.
Gifts and Hospitality
We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly.
No gift should be given, nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a director.
Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a director.
Record Keeping
A record will be made by a director of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
This Policy has been approved and authorised by:
| Name: | Matthew Woodhart |
| Position: | Managing Director |
| Date: | October 2024 |
| Due for Review by: | October 2025 |