MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT REV 1.0, 08/2021
This statement is provided for Thirdway Group Ltd (Thirdway) and on behalf of Thirdway’s subsidiary companies as listed at the end of this statement.
Our position on human rights within Thirdway is clear and covered in our Code of Conduct. We respect the human rights of all our employees and those within our supply chain and have zero tolerance of slavery and human trafficking.
We are committed to ensuring that slavery, trafficking, bonded labour, forced or servile marriage, descent-based slavery and domestic work and slavery does not take place in our business or any part of our supply chain by seeking to;
· Ensure our recruitment processes are transparent and reviewed regularly, with robust processes in place for the vetting of the appointment of our people;
· Raise awareness of the issue amongst our people and our suppliers & subcontractors to combat the hidden nature of modern slavery;
· Challenge and support our suppliers & subcontractors in the effort to drive out modern slavery and human trafficking; and
· Apply the spirit, as well as the letter of the law, to our internal practices.
This Statement sets out the steps which Thirdway has taken during the business period ending the 31st of August 2021 to help ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
Thirdway is a London-based design and build, furniture, architecture, and development company.
Our Supply Chain
As a company predominately offering design, fit-out and construction services to our clients, our supply chain is characterised by skilled technical contractors and trades.
Occasionally we use temporary labour to support our operational requirements in certain areas (e.g. cleaners and site employees). The materials we buy are in support of the services we deliver.
Our governance in relation to slavery and human trafficking
We have an established set of policies and procedures covering human rights in general and specifically addressing relevant areas to minimise the risk of slavery or human trafficking occurring in our businesses or supply chains.
Our relevant policies and procedures include:
· Our Code of Conduct statement
· Our Recruitment Procedure;
· Our Supplier Selection Process; and
· Our Whistleblowing Procedure.
Code of Conduct and Ethical Behaviour
Our Code of Conduct forms the cornerstone of our wider ethical business framework. It provides our people with the guidance and support necessary to carry out their work in the right way. We designed our code to help our people understand Thirdway’s core values and the responsible behaviours which underpin them. It provides guidance and support for all Thirdway personnel when undertaking their work and draws together all of our long-standing policies and procedures from all business areas into one simple and practical guide.
We demand the highest levels of ethical and moral stewardship within Thirdway. We are committed to being a responsible business and to developing mutually beneficial and sustainable relationships with our stakeholders and business partners, based on trust and co-operation.
Over and above the requirements of the Modern Slavery Act 2015, we strive to ensure that employment is chosen freely; freedom of association is respected; working conditions are safe and hygienic; child labour is not used; wages are not lower than minimum wage; working hours are not excessive; no discrimination is practised; regular employment is provided; and no harsh or inhumane treatment is allowed.
We endeavour to carry out appropriate checks to ensure that any new applicant is suitable for the role that they have applied for. Prior to making an offer, it is our usual practice to ensure that all applicants are aware of what checks we will carry out. We make job offers subject to appropriate satisfactory vetting procedures (where required).
All our people undergo identity and Right to Work checks prior to commencing employment followed by reference checks. We employ most of our people directly or on a fixed-term basis with checks in place to ensure that payment of salary is made direct to that person.
Our Recruitment Procedure outlines the mandatory requirements we impose, which includes the requirement to use approved agencies in the recruitment process. Our Recruitment Procedure seeks to ensure that third party providers can demonstrate that they comply with all legal requirements, including the requirement to comply with the Modern Slavery Act 2015.
Employee awareness and compliance
Our Employee Handbook and Code of Conduct set out our policies and key procedures. We give all our people access to the Handbook and a summary version of our Code of Conduct when they begin working for Thirdway. We also provide our line managers with a detailed copy of the Code of Conduct.
These core documents, together with our targeted awareness programmes on modern slavery and human trafficking, helps us to deliver our key messaging so that our people can comply with our requirements.
All these documents are available internally.
We expect our suppliers and other business partners to have the same high standards as we impose on our own business. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.
As part of our on-boarding process, our suppliers & subcontractors are required to complete our pre-qualification questionnaire acknowledging and aligning to our own stance on modern slavery.
Our Standard Terms and Conditions require our suppliers to comply with all legal requirements, including adherence to the Modern Slavery Act 2015.
Business and supply chain risk assessment and risk management
With the introduction of the Modern Slavery Act 2015, we assessed our supply chain for potential areas of increased risk of non-compliance to the Act. We continue to do this and, where areas are identified, we carry out an audit, which will include a focus on compliance with employment as well as other regulatory and sustainability criteria. The defined criteria for assessing potential areas of risk within our supply chain are:
· Companies that operate using temporary low skilled labour;
· Operations outside of the UK / EU regulatory frameworks;
· Manufacturing or trading in raw materials produced in non-UK/EU areas;
· Companies that have a strategic partnership with Thirdway.
We enforce our policies and procedures in an effort to ensure that slavery and human trafficking is not taking place anywhere in our business or supply chain.
Our supplier on-boarding process includes standard due diligence procedures, which help us assess the suitability of a vendor to provide goods and services to Thirdway against compliance to required standards. This process captures confirmation that they are committed to ensuring that slavery and human trafficking is not taking place within their own supply chain. Tender and supplier selection processes also include checks for acceptance of Thirdway’s terms and conditions.
Our procurement team carries out desktop audits as part of our supply chain management to provide assurance that our suppliers are responsible partners in our service delivery.
The effectiveness of our processes
We implement the following key performance indicators (KPIs) to ensure compliance to the Modern Slavery Act 2015 and the effectiveness of our policies and procedures:
· 100% of our suppliers and supply chain to have agreed to our Terms and Conditions of engagement.
· 100% of new suppliers to have undergone suitability assessments during our onboarding process via our supplier pre-qualification checks.
· 100% of all new-starter inductions to include discussion and raise awareness of modern slavery.
· Carry out internal awareness campaign annually targeted at all employees regarding modern slavery.
Training on slavery and human trafficking
We believe that improved awareness is one of our most effective methods to reduce the risk of modern slavery and with the help of both our employees and suppliers we aim to ensure that there are no opportunities to hide forced labour within our organisation or our supply chain.
We continue to strengthen employee awareness of our stance on modern slavery and human trafficking. We do this by introducing topics aligned with our understanding of these issues during the initial induction process of new employees. This is following up by annual awareness campaigns targeted at the whole business.
This complements the training created for our people, so they understand the issues involved, become more aware of the risks, the signs to be vigilant of and how to raise awareness should they see or fear something suspicious.
We encourage our people, customers and suppliers to report any concerns about unlawful conduct that they suspect is taking place at work. This includes any concerns regarding the risk of slavery or human trafficking.
Our Whistleblowing procedure provides our people and our business partners with the ability to report suspected wrongdoing. This procedure enables concerns to be reported without fear of retaliation in the knowledge that we do not tolerate harassment, victimisation or reprisals against anyone raising a concern in good faith.
In addition, employees who believe that they have come across an instance of modern slavery (or who may be a victim) and who need information and/or guidance on remedy, compensation and justice will be advised of their right to contact the Modern Slavery Helpline and/or other specialist support and assistance providers across the UK.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and Public Interest Act 1998, and constitutes Thirdway Group’s slavery and human trafficking statement for the business period ending 30 August 2022.
Signed for and on behalf of Thirdway Group Ltd
Ben Gillam CEO and Owner