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Modern Slavery Statement

Introduction

Amalgamated Construction Ltd (AmcoGiffen) is fully committed to the prevention of Modern Slavery and Human Trafficking and will not tolerate or condone any such identified act within any aspect of our business activities.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015, it sets out the activities undertaken by the Company in respect of the prevention of Modern Slavery and Human Trafficking and constitutes the Company’s annual statement for the financial period 1 October 17 to 30 September 18.

Organisational Structure

AmcoGiffen and its subsidiaries provide a diverse range of specialist construction and engineering services in support of the creation and maintenance of assets for both public and private sector customers in the Infrastructure Sector. Our work is conducted solely in the United Kingdom and delivered by a directly employed workforce all of whom are fully eligible to work within the United Kingdom.

Supply Chain

Given the nature of our organisational structure, model of directly employed work delivery and our use of a UK based Supply Chain, we consider that any exposure to risk of Modern Slavery or Human Trafficking is extremely low and that should any risk exist it is most likely to be within the extended Supply Chain. We work closely with Tier 1 members of our Supply Chain in the identification of such risk to ensure it is addressed in an appropriate manner.

Modern Slavery Policy

AmcoGiffen has implemented a comprehensive policy in respect of Modern Slavery and Human Trafficking. This policy and supporting procedures detail our business approach to the prevention of Modern Slavery and Human Trafficking, along with the processes used to support and deliver our commitment. This policy and commitment has been communicated to our employees and Tier 1 Supply Chain partners for their information and action.

We operate a risk based approach to the identification of Modern Slavery and Human Trafficking, the principle of which is based on the location of the product or service, industry sector, supplier relationships and existing data held supported by additional information and guidance obtained from, but not limited to, sources such as the Global Slavery Index, Corruption Perceptions Index and US Department of Labour Lists of Goods and Suppliers.

Due Diligence and Identification of Risk

AmcoGiffen’s policy of direct employment is supported by robust processes which ensure that an individual’s identity is confirmed and they have a legitimate right to work in the United Kingdom. This policy and the right to work checks undertaken by our staff significantly reduces the risk of directly employing forced labour or those who may be subject to human trafficking.

Where AmcoGiffen do utilise labour only sub-contractors we are introducing due diligence checks to ensure that, as a minimum, labour providers comply with our commitment to the Prevention of Modern Slavery and their processes for recruitment contain no illegal labour practices.

Notwithstanding that AmcoGiffen’s Supply Chain is primarily UK based, we have instigated a risk assessment of supply chain activities to identify and prioritise any areas which may pose a risk of Modern Slavery.

Our activities during 2017/18 included:

  • Completing a data analysis in respect of identified high risk suppliers and monitoring the identified high risk suppliers. A defined programme of desktop audits was undertaken in relation to identified key high risk suppliers.
  • Continuous review of our Procurement and Supply Chain and their processes to understand the activities they undertake to ensure that Modern Slavery and Human Trafficking is not taking place in our supply chain.
  • Incorporating our Modern Slavery requirements into our supplier reviews and Vendor Assessment and Appraisal process for new suppliers. All existing suppliers must renew their Vendor Assessment after a period of three years, this therefore ensures that all new suppliers are immediately included and that remaining Tier 2 and 3 elements of the existing AmcoGiffen supply chain will have been captured by the latter part of 2019 at the latest.

Our objectives for the financial year 2018/19 include:

  • To undertake a continued programme of supply chain desk top audits of specifically identified high and medium risk suppliers.
  • To undertake a further review of our existing supply chain to ensure that any potential new or existing suppliers have not changed their status in term of “risk”.
  • Engaging with our Key Strategic Suppliers and Industry bodies to engage with their Supply Chains to discuss and understand capability, best practice and learning on Modern Slavery to continuously improve our approach to Modern Slavery.
  • Incorporating Modern Slavery as a priority into 360 degree reviews with Key Supply Chain partners to ensure no new risks of Modern Slavery have been introduced in their practices.

 Communication and Training

Our commitment to the prevention of Modern Slavery and Human Trafficking emanates directly from our Board of Directors. Their leadership and commitment to this important social issue has been clearly communicated both internally to employees and externally to subcontractors and Tier 1 Supply Chain partners.

Whilst all employees have received awareness training in relation to Modern Slavery, employees who have a direct responsibility and involvement for the engagement of workers and for dealing with supply chain matters have, or will, receive appropriate levels of training in these issues.

Commitment

The Board of Directors have reviewed this statement and formally approved it on the 29th April 2019.

We acknowledge that we are still in the early stages of a long term strategy and our approach to the Prevention of Modern Slavery and Human Trafficking will undoubtedly evolve year on year. We will utilise our annual statements to publicly reaffirm our continued commitment and communicate this evolution, including the steps we have taken and will continue to take, to deal with this morally and socially important issue.

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