Modern Slavery and Human Trafficking

Policy and Statement

Statement

This statement has been published in accordance with Section 54 of the UK Modern Slavery Act (2015). It sets out the steps taken by Ringway Jacobs Limited to prevent modern slavery and human trafficking within our business and supply chain during year ending 31st December 2019.

Ringway Jacobs Limited is a leading highways service provider working with local authorities across the UK, with an annual turnover in the region of £300 million. We currently operate in Cheshire East, Buckinghamshire, Central Bedfordshire, Essex and Central and North East areas of London.

Ringway Jacobs Limited has a Code of Conduct and Ethics and the principles of this code are reflected within this statement.

Our Modern Slavery and Human Trafficking policy continues to be communicated to our employees and our supply chain and is embedded in to the way we work.

Our supply chain comprises subcontractors of all sizes that provide specialist services. Subcontracted works account for approximately 70% of our turnover with further services being delivered directly by in house teams, with materials being sourced from external suppliers/manufacturers. Over a year we may contract with around 300 subcontractors across the UK. Our supply chain is integral to our operations and our success and reputation is inextricably linked to their performance and ethical standards.

Our overarching supply chain strategy is to build long-term relationships with a consolidated number of high performing subcontractors and suppliers.

Ringway Jacobs Limited operate to a company-wide set of policies and procedures that govern the way we engage with our supply chain, in a fair manner, paying promptly and developing relationships with companies that work safely, provide good quality and embrace our ethical standards.

Our policies explicitly state how we operate as a business and the steps we take to ensure that we are a transparent, accessible and inclusive organisation. These policies are reviewed regularly and updated to ensure that ongoing opportunities for improvement are identified and acted upon. These policies are available for viewing by all Ringway Jacobs Limited personnel via our internal policy portal and include:

• Code of Conduct and Ethics

• Social Value

• Anti-Bullying and Harassment

• Anti-Bribery

• Equality and Diversity

• Recruitment and Selection

• Modern Slavery and Human Trafficking

• Whistleblowing

Employees must ensure that they read and comply with these policies and understand that the prevention and reporting of modern slavery in any part of the business and supply chain is the responsibility of all those working directly for Ringway Jacobs and those under its control.

Ringway Jacobs Limited acknowledge that the construction sector can be particularly vulnerable to targeting by those responsible for slavery and trafficking. Construction is labour intensive, often working to tight commercial margins and works may well be spread across numerous subcontractors who themselves may on occasion sub- subcontract. We focus strongly on not only developing robust policies but also enforcing them and educating our direct and subcontract workforces.

We carry out right to work and pre-employment checks on all employees joining our organisation and this includes the employee being able to provide evidence that they are in possession of their own identification documents and that the bank account details provided belong to the employee and not a third party. Any discrepancies identified are investigated thoroughly and appropriate action taken.

All subcontractors and suppliers working for us have to prequalify to be approved. Specific questions relating to modern slavery, equality, diversity and inclusion, social values and the Bribery Act must be addressed satisfactorily. This approach is taken for all subcontractors and suppliers prior to commencing any works.

Our whistleblowing policy applies to all employees of Ringway Jacobs. Other individuals performing functions in relation to the organisation, such as agency workers and contractors, are also encouraged to use it. This allows safe reporting by any individual of any wrongdoing including human rights abuses either being directly experienced or witnessed. Individuals are encouraged to raise such concerns with their line managers but are free to contact Safecall, a third party whistleblowing helpline, should they prefer.

2019 Activities

During the course of 2019, we undertook a range of actions to further our effectiveness in preventing modern slavery and human trafficking:

• Appointed a sustainability business partner, part of whose role is to increase our knowledge and outputs in the area of modern slavery and social value.

• Created a new role and successfully appointed a supply chain manager to improve co-ordination and control of our procurement across our business.

• Became partners of the Supply Chain Sustainability School, having identified the potential benefits for training both our supply chain and direct employees in matters of sustainability, modern slavery and fairness and inclusion

• Continued to ensure that all our employees are trained to understand their personal and collective responsibilities to identify and manage potential incidents of modern slavery and human trafficking.

Activities planned for 2020

• Using the Supply Chain Sustainability School’s portal to carry out formal, CPD accredited training of our key subcontractors for awareness of modern slavery and human trafficking.

• Record and audit this training to form part of our key performance indicators (KPI’s).

• Utilise the Supply Chain Sustainability School resources to further enhance the education of our staff and

include the records for future KPI’s.

• Identify and deliver more specific extra training for our supervisors and managers who regularly interface

with subcontractors on site, to highlight warning signs relating to modern slavery and human trafficking. • Identify potentially higher risk areas within our supply chain for both suppliers and subcontractors and

agree an action plan to further investigate risk levels and mitigations.

In addition, our teams responsible for both subcontract and material procurement will undergo additional training to increase their awareness of modern slavery and human trafficking.

We regularly hold supply chain events and will now invite representatives from the Supply Chain Sustainability School to give specific talks on modern slavery and trafficking as well as fairness, inclusion and respect.

All new direct employees will complete a modern slavery e-learning module as part of their on-boarding process, to establish a base line level of understanding.

This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 and constitutes Ringway Jacobs Limited’s Modern Slavery and Human Trafficking Statement for the financial year ended 31st December 2019. It was approved by the Board on 1 April 2020.