FORCED LABOUR & HUMAN TRAFFICKING POLICY
Andrew Michael Ltd is committed to driving out acts of forced labour and human trafficking within its business and that from within its supply chains, including subcontractors, and partners.
The policies we have in place and this anti-forced labour statement, reflect our commitment to:
• Paying people fairly and properly for their work.
• Acting ethically and with integrity in all our business relationships.
• Enforcing effective systems and controls to ensure forced labour and human trafficking is not
taking place anywhere in our business or supply chains.
The Company acknowledges responsibility to the Forced labour Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation.
Employees
All employees who join us are subject to checks to ensure they are genuine applicants operating as free agents with the required level of propriety. These will include verification of identity, references, evidence of qualifications, and may include criminal and financial checks.
Suppliers / Subcontractors
We operate a supplier/subcontractor verification process. We give all suppliers/subcontractors a copy of our anti-forced labour statement, request and review a copy of their statement, as well as undertaking a number of due diligence checks on them.
As part of the company’s due diligence processes into forced labour and human trafficking, the supplier/subcontractor approval process incorporates a review of the controls undertaken by the supplier/subcontractor.
Imported goods from sources from outside the UK and EU are potentially more at risk for forced labour/human trafficking issues. The level of management control required for these sources will be continually monitored.
For suppliers/subcontractors where there is deemed to be an additional risk of forced labour or human trafficking, supplementary checks are completed.
The Company will not support or deal with any business knowingly involved in forced labour or human trafficking.
The Company Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc) and investment to ensure that forced labour and human trafficking is not taking place within the organisation and within its supply chains.
The implementation and operation of this management system underlines our commitment to this policy.
Authorised by the Directors, for and on behalf of Andrew Michael Ltd:
Michael E. Smith BEng(Hons), MSc, MEI
Managing Director
Andrew Michael Ltd is committed to driving out acts of forced labour and human trafficking within its business and that from within its supply chains, including subcontractors, and partners.
The policies we have in place and this anti-forced labour statement, reflect our commitment to:
• Paying people fairly and properly for their work.
• Acting ethically and with integrity in all our business relationships.
• Enforcing effective systems and controls to ensure forced labour and human trafficking is not
taking place anywhere in our business or supply chains.
The Company acknowledges responsibility to the Forced labour Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation.
Employees
All employees who join us are subject to checks to ensure they are genuine applicants operating as free agents with the required level of propriety. These will include verification of identity, references, evidence of qualifications, and may include criminal and financial checks.
Suppliers / Subcontractors
We operate a supplier/subcontractor verification process. We give all suppliers/subcontractors a copy of our anti-forced labour statement, request and review a copy of their statement, as well as undertaking a number of due diligence checks on them.
As part of the company’s due diligence processes into forced labour and human trafficking, the supplier/subcontractor approval process incorporates a review of the controls undertaken by the supplier/subcontractor.
Imported goods from sources from outside the UK and EU are potentially more at risk for forced labour/human trafficking issues. The level of management control required for these sources will be continually monitored.
For suppliers/subcontractors where there is deemed to be an additional risk of forced labour or human trafficking, supplementary checks are completed.
The Company will not support or deal with any business knowingly involved in forced labour or human trafficking.
The Company Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc) and investment to ensure that forced labour and human trafficking is not taking place within the organisation and within its supply chains.
The implementation and operation of this management system underlines our commitment to this policy.
Authorised by the Directors, for and on behalf of Andrew Michael Ltd:
Michael E. Smith BEng(Hons), MSc, MEI
Managing Director
Our Business and Supply Chains
Policies and Contractual Controls
We recognise that slavery, servitude, forced labour and human trafficking, is a growing issue worldwide. We have a zero tolerance approach towards forced labour both in our own operations and our supply chain.
Our procurement policy is to source goods and services efficiently and fairly. Our procurement methods are compliant with legislation, including health and safety regulations, and conform to our ethical, environmental and responsible business standards.
Our Ethics policy states that we will not tolerate abuse of human rights in any part of our business or supply chain and will take seriously any allegations that human rights are not properly respected.
All our suppliers are required to comply with this policy.
We also operate a whistle blowing policy, aimed principally at our employees but also available to others working on our projects, that encourages employees to report any wrongdoing including human rights abuses.
All reports are formally investigated and appropriate action taken. Our policies are developed by experts in the subject and approved by the Board.
Our minimum trading standards require all our suppliers to:
• Provide their employees with good working conditions and fair treatment.
• Respect workers’ human rights and comply fully with all applicable laws.
• Ensure all work is voluntary, and not done under any threat of penalties or sanctions.
• Not require workers to pay any deposits for work, and employers - whether labour
users or recruiters – must not keep original copies of identity documents.
• Ensure that workers are free to leave work at any time, with all salary owed to be paid.
• Comply with the Modern Slavery Act;
• implement appropriate controls to prevent Forced labour.
• notify Management immediately if they become aware of any forced labour within
Their supply chains.
Appropriate action will be taken against suppliers who breach these obligations, which may include terminating their contract. We are also reviewing the remedies that we would expect our suppliers to implement if we were made aware of any incidents of Forced Labour and Human Rights abuses.
Due diligence and audits of our supply chain
Our main exposure to forced labour is through suppliers of labour for our projects and suppliers that procure products from high risk territories overseas. As part of our existing due diligence and risk assessment process, all our supply chain must obtain clearance for approval to work with us.
Post approval, we a wide range of matters. Over the next year we will reserve a contractual right to carry out periodic compliance audits and/or request additional information and evidence in respect of compliance with the Forced labour Act 2015 (Transparency in Supply Chains) (‘the Act’) (where applicable) and the standards we have set in relation to the risk management of anti-slavery and human trafficking in the supply chain.
Assessment of Forced labour risk within our supply chain
Our larger subcontractors and suppliers and joint venture partners (the majority of whom are UK based) are considered lower risk as they are themselves required to comply with the Act.
We expect that they will undertake their own risk assessment and management relating to slavery and human trafficking. However, we will seek further assurances from suppliers who procure labour and materials from the UK and overseas under various sub-contract arrangements. The extent of the risk will depend on the country of origin of the labour or materials.
Effectiveness in preventing Forced labour
We will be reporting against the following key performance indicators in our future Forced labour statements:
• staff training levels.
• mapping exercise of the supply chain.
• the development of a due diligence questionnaire.
• progress with the Supply Chain Sustainability School members to develop an industry
review and audit process for common suppliers.
• investigations undertaken into reports of Forced labour and remedial actions taken in
response.
Responsibility for compliance
The Managing Director is responsible for supplier relationships and for the company’s Forced Labour Policy and the Act.
Policies and Contractual Controls
We recognise that slavery, servitude, forced labour and human trafficking, is a growing issue worldwide. We have a zero tolerance approach towards forced labour both in our own operations and our supply chain.
Our procurement policy is to source goods and services efficiently and fairly. Our procurement methods are compliant with legislation, including health and safety regulations, and conform to our ethical, environmental and responsible business standards.
Our Ethics policy states that we will not tolerate abuse of human rights in any part of our business or supply chain and will take seriously any allegations that human rights are not properly respected.
All our suppliers are required to comply with this policy.
We also operate a whistle blowing policy, aimed principally at our employees but also available to others working on our projects, that encourages employees to report any wrongdoing including human rights abuses.
All reports are formally investigated and appropriate action taken. Our policies are developed by experts in the subject and approved by the Board.
Our minimum trading standards require all our suppliers to:
• Provide their employees with good working conditions and fair treatment.
• Respect workers’ human rights and comply fully with all applicable laws.
• Ensure all work is voluntary, and not done under any threat of penalties or sanctions.
• Not require workers to pay any deposits for work, and employers - whether labour
users or recruiters – must not keep original copies of identity documents.
• Ensure that workers are free to leave work at any time, with all salary owed to be paid.
• Comply with the Modern Slavery Act;
• implement appropriate controls to prevent Forced labour.
• notify Management immediately if they become aware of any forced labour within
Their supply chains.
Appropriate action will be taken against suppliers who breach these obligations, which may include terminating their contract. We are also reviewing the remedies that we would expect our suppliers to implement if we were made aware of any incidents of Forced Labour and Human Rights abuses.
Due diligence and audits of our supply chain
Our main exposure to forced labour is through suppliers of labour for our projects and suppliers that procure products from high risk territories overseas. As part of our existing due diligence and risk assessment process, all our supply chain must obtain clearance for approval to work with us.
Post approval, we a wide range of matters. Over the next year we will reserve a contractual right to carry out periodic compliance audits and/or request additional information and evidence in respect of compliance with the Forced labour Act 2015 (Transparency in Supply Chains) (‘the Act’) (where applicable) and the standards we have set in relation to the risk management of anti-slavery and human trafficking in the supply chain.
Assessment of Forced labour risk within our supply chain
Our larger subcontractors and suppliers and joint venture partners (the majority of whom are UK based) are considered lower risk as they are themselves required to comply with the Act.
We expect that they will undertake their own risk assessment and management relating to slavery and human trafficking. However, we will seek further assurances from suppliers who procure labour and materials from the UK and overseas under various sub-contract arrangements. The extent of the risk will depend on the country of origin of the labour or materials.
Effectiveness in preventing Forced labour
We will be reporting against the following key performance indicators in our future Forced labour statements:
• staff training levels.
• mapping exercise of the supply chain.
• the development of a due diligence questionnaire.
• progress with the Supply Chain Sustainability School members to develop an industry
review and audit process for common suppliers.
• investigations undertaken into reports of Forced labour and remedial actions taken in
response.
Responsibility for compliance
The Managing Director is responsible for supplier relationships and for the company’s Forced Labour Policy and the Act.