Issue Date: January 2024
Next Review: January 2025
MODERN SLAVERY STATEMENT
Introduction
This statement sets out the Company actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
As part of the engineering sectors, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.
The Board of Directors is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational Scope
This statement covers all activities of the Company, a family-owned business that operates within the Construction and Engineering Industry. Its main business activities include civil, mechanical, process engineering and MEICA engineering, including full EPC services for private and public sector clients.
Key sectors include process & water, energy, oil & gas and nuclear. The Company applies total engineering throughout the project lifecycle from design development through to commissioning and handover.
Services are provided for Clients both in the United Kingdom and internationally, employing circa of 800 people, 250 of which are field based operatives. To find out more about the nature of the business please click www.trant.co.uk
Countries of operation and supply
The Company currently operates in the following countries:
In order to undertake its operations, the Company works with a range of suppliers including subcontractors, suppliers of materials and recruitment agencies.
The Company expectations and standards are communicated throughout the supply chain to set the standard of operation. It is the Company’s ethos to build strong relationships with the supply chain to understand their policies and compliance to assess any potential risks. The Company’s supplier approval process incorporates a review of controls undertaken by the supplier to assess compliance.
Responsibility for our anti-slavery initiatives is as follows:
Policies: The HR Department will plan and review policies in conjunction with the SHEQ & Systems Departments. Key Stakeholders have been involved in the development of policies including the Procurement Director, the Finance Director and the commitment from the Managing Director and Board of Directors. The Quality department ensures governance and compliance.
Risk Assessments: The Company has formulated a modern slavery implementation plan which is reviewed with the Finance Director and Procurement Director and key stakeholders. The Procurement Director in liaison with the Finance Director have undertaken risk analysis on the supply chain, categorising suppliers as high / medium or low risk and implemented necessary action planning. All new suppliers to the Company must undergo a compliance exercise through our supplier questionnaire prior to any engagement.
Investigations and Due diligence: An audit process through our supply chain will be undertaken by Company auditors in order to ensure compliance with the Company and legislative values and standards. Any supplier or site or department who does not comply will be issued with non-conformances and be expected to rectify. The Company will provide guidance, help and support to ensure compliance.
Training: The Company has undertaken toolbox talks and issued publication material to be displayed on notice boards to raise awareness of modern slavery. It is the responsibility of all site management to ensure that staff have awareness. The Company will be rolling out a Modern Slavery e-learning package to staff and suppliers.
Policies
As part of the Company’s commitment to addressing and opposing modern slavery there is a range of policies
to identify modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
No Blame and Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or those of its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Our suppliers are made aware of the Policies and are required to adhere to the same standards.
Due Diligence
As part of the Company’s due diligence processes our supplier approval process is being developed to incorporate the following:
The procedures the Company is adopting have been designed to:
Risk and Compliance
As part of the Construction and Engineering sector, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking as the industry has historically been found to be a highly targeted industry.
The Company assesses whether or not particular activities or countries are a high risk in relation to slavery or human trafficking by researching and assessing:
The country in which the business operates specifically in countries where human rights are limited.
High-risk activities
The following aspects are considered to be at high risk of slavery or human trafficking:
It is known that the construction industry and construction sites have been historically targeted by the trafficking regime and is considered to be of high risk to the Company operating within the said industry. The Company are committed to mitigating this risk through stringent identification checks of all staff directly employed by the Company, security clearance processes and complying with our contractual obligations for staff.
The Company also expect all recruitment agencies to follow Company policies and the Company only use approved reputable recruitment agencies. To ensure the potential for slavery and human trafficking is reduced as far as possible, the Company thoroughly check recruitment agencies before adding them to our list of approved agencies.
The Company also engages the services of subcontract labour both within the UK and internationally which is considered as high risk. The Company ensures that the supplier approval process is followed, and the Company applies its stringent subcontract assessment processes in compliance with pas91.
The Company has identified that supply of goods sourced from outside of the UK pose a high risk. To mitigate this the Company will check supply chains to ensure the potential for slavery and human trafficking is significantly reduced. The Company informs suppliers that we intend to engage with, that the Company is not prepared to accept any form of exploitation.
Performance indicators
The Company will instigate the following measures to monitor performance:
Training
The Company is committed to educating staff to recognise modern slavery and human trafficking in the Company and supply chains. The training programs will raise awareness, help to identify risk and encourage employees to report any breaches of this statement.
The Company's modern slavery training will cover:
Awareness-raising Programme
As well as training staff, we have raised awareness of modern slavery issues by distributing flyers to staff/putting up posters across our premises.
The flyers/posters explain to staff:
Board/Member Approval
This statement was approved by our board of directors/members, who review and update it annually.
G Somers
Managing Director