Modern Slavery Policy

Engage Construction is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

 

We are committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

 

Engage Construction provides appropriate training and awareness information for all of its staff.  In particular, our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.

 

Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to [identify an appropriate contact(s), by name or by role].

 

Reports surrounding these issues are taken extremely seriously by our board of directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

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• Working with the appropriate organisations to improve standards,

• Removing that organisation from our preferred supplier list,

• Passing details to appropriate law enforcement bodies.

 

We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

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• The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements,

• The effectiveness of enforcement against suppliers who breach policies,

• The amount of time spent on audits, re-audits, spot checks, and related due diligence, and

• The level of modern slavery training and awareness amongst our staff.

 

As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

 

We would also recommend reading this in conjunction with our other policies, including our:

 

• Corporate social responsibility policy,

• Ethical procurement policy,

• Anti-bribery / corruption policy, and

• Whistle-blowing policy.

 

This policy was adopted 1st Feb 2023 after being agreed upon by our board of directors.  It is reviewed annually.

 

Modern Slavery Policy

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This statement is made as part of Engage Construction’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how Engage Construction operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act and relates to the financial year April 2022 to April 2023].  [see Note 1]  It was approved by the board of directors on 1st Feb 2023.

 

Our Business

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TWRG Holdings Ltd is a limited company operating in the recruitment sector operating with the trading name of Engage Construction.  We provide introduction services / supply temporary workers in the Residential, Main Contracting, Sub Contracting, Trades & Labour, Mechanical & Electrical, Cleaning Services sectors within the Construction industry.

 

Who we work with

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All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff.  All of the temporary workers we supply are identified by our staff.

 

The hiring companies that we work with are located in London and the South East of England.

 

Other relationships

 

As part of our business, we also work with the Recruitment and Employment Confederation (www.rec.uk.com).

 

Our Policies

 

Engage Construction has a modern slavery policy. In addition, we also have the following policies which incorporate ethical standards for our staff.

 

·        Corporate social responsibility policy

·        Ethical procurement policy

·        Anti-bribery / corruption policy, and

·        Whistle-blowing policy.

 

Policy Development

 

Our policies are established by our senior leadership team, based on advice from HR professionals within the REC, who provide industry best practices and legal advice, and in consultation with our board of directors.  We review our policies annually, or as needed to adapt to changes.

 

Risk Management

 

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

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We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks. After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain.  However, we continue to be alert to the potential for problems.

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We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.

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We require the businesses we work with to address modern slavery concerns in their policies and publish a modern slavery statement.

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We collaborate with our suppliers in order to improve standards and transparency across our supply chain.

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Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.

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Our staff are encouraged to bring any concerns they have to the attention of management.

 

Our Performance

 

Based on the potential risks we have identified, we have established the following key performance indicators, which are regularly assessed by our senior leadership team:

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• the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements

• the amount of time spent on audits, re-audits, spot checks, and related due diligence

• the level of modern slavery training and awareness amongst our staff

 

We benchmark our indicators against industry best-practice, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

 

Our Training

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All of our staff receive training and support that is appropriate to their role.  In particular:

 

• Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.

• Our recruiters undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking so that they can bring any concerns they have to the attention of management.

 

As part of this, our staff are encouraged to discuss any concerns that they have.

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Training is refreshed annually.