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 March 2021.

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 and Essex.

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 of 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 and have access to Safecall, a third party whistleblowing helpline, should they prefer.

2020 Activities

During the course of the 2020/21 financial year, we undertook a range of actions to further our effectiveness in preventing modern slavery and human trafficking:

  • Held a Modern Slavery workshop (hosted by the Supply Chain Sustainability School) attended by several representatives of our key subcontractors and Ringway Jacobs direct personnel.
  • Developed a new modern slavery tool box talk for use across all contracts.
  • Renewed our partnership of the Supply Chain Sustainability School and were awarded Gold status.
  • A revised modern slavery training module written and implemented as part of mandatory training for all Ringway Jacobs staff.
  • Obtained multi lingual slavery reporting posters/cards/literature that were distributed across all contracts for display in open areas and sites.
  • 38 of our key subcontractors and suppliers have joined the Supply Chain Sustainability School.
  • Initial heat mapping of key material suppliers carried out.

Activities planned for 2021

  • Carry out further training of our key subcontractors and suppliers to raise awareness of modern slavery and human trafficking. This will comprise another workshop hosted by the Supply Chain Sustainability School and aforementioned tool box talks.
  • 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 further specific training for our supervisors and managers who regularly interface with subcontractors on site, to highlight warning signs relating to modern slavery and human trafficking.
  • Having identified potentially higher risk areas within our supply chain for suppliers, to agree an action plan to further investigate risk levels and mitigations.
  • Revisit supply only and subcontract terms and conditions to reinforce our supply chains’ responsibility to reduce the likelihood of modern slavery within their organisations and supply chains.
  • Continue mandatory modern slavery awareness training for all new staff.

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

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

March 2021. It was approved by the Board on 16th July 2021.

Signed

Philip Horton

Managing Director

Ringway Jacobs Limited