Policy Purpose

 

At Reach CM Limited, we recognise that slavery and human trafficking are significant human rights issues. We are committed to adherence to the Modern Slavery Act 2015, and are taking appropriate and proportionate steps to mitigate the risk of these occurring within our business and our supply chain.

 

We have agreed management responsibility for this policy and statement and have received unanimous endorsement from our Key Principals.

As a construction business operating within the UK, the key areas of our operation that could be affected by slavery and human trafficking are our directly hired employees, agency workers working on our behalf, contractors, subcontractor operatives working on our sites, and the workforce of our supply chain who supply materials to our business.

 

Scope:

 

This Policy applies to:

• All employees, contractors and temporary start

• Subcontractors, supplier and business partners

• All locations where Reach CM Limited operates, including construction sites and offices

​

Policy Statement

​

Reach CM Limited take a zero-tolerance approach to modern slavery and human trafficking. We expect the same high standard from our suppliers and subcontractors. Any breach of this policy may result in disciplinary action, termination of contracts, or reporting to relevant authorities.

​

Responsibilities

• Board/Senior Management: Approve and review this policy, ensure resources for compliance and monitor effectiveness

• Procurement Team: Ensure supplier due diligence, include anti-slavery clauses in contracts and monitor compliance

• Site Managers/Supervisors: Identify and report any potential risks on project sites

• All Employees: Follow the policy, report concerns and participate in training

​

Due Diligence and Risk Management

 

Employees

• We verify that all employees have the right to work in the UK upon commencement of their employment.

• We make all employees aware of their working hours, leave and absence entitlements and other employment benefits via the Employee Handbook.

• We require all relevant personnel to undertake modern slavery awareness training.

 

Agency workers

• We aim to only engage agency workers that are provided by approved suppliers.

• We require all approved suppliers to ensure their agency workers have the right to work in the UK and to have procedures in place to minimise the risk of recruiting forced or compulsory labour.

 

Contractors and Subcontractors

• We require Contractors and Subcontractors to ensure their employees have the right to work in the UK.

• We consider Contractors’ and Subcontractors’ approaches to employee rights and any breaches of human rights- related legislation during our selection process.

• We ask all site operatives to provide evidence of their CSCS cards.

• We want all Contractors and Subcontractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.

 

Suppliers

• We procure the majority of our directly-sourced materials from UK based organisations that are required to comply with UK laws on forced labour.

• Where materials are directly sourced from outside the UK, we consider the risk of slavery and human trafficking as part of our selection process.

 

Training and Awareness

​

We will provide training to:

• Site managers and supervisors on identifying and reporting modern slavery risks

• Procurement staff on ethical sourcing and supplier due diligence

• All employees during induction and periodic refresher sessions

 

Reporting and Whistleblowing

• Our whistleblowing procedure allows any employee or third party to confidentially raise a concern.

• All reports of concerns will be investigated promptly

 

Monitoring and Review

 

The effectiveness of this policy will be monitored through:

• Supplier compliance audits

• Risk assessments completion

• Investigations of reported concerns

• Annual review by a senior manager

 

This policy will be reviewed at least annually and updated as necessary to reflect changes in legislation or company practices