Modern Slavery and Human Trafficking Statement  

This statement of compliance with Section 54 of the Modern Slavery Act 2015, sets out the actions that ECL Engineering Ltd (referred to in this statement as “ECL”) has taken to ensure that modern slavery and human trafficking is not occurring in our organisation or in our supply chains.  

This statement is for the financial year ending July 2026. 

ECL’s organisational structure, business, and supply chains  

ECL is a top civil engineering and groundworks firm serving Bedfordshire and Northamptonshire in housing construction. Working with some of the UK’s biggest developers, ECL provides civil engineering solutions including enabling works, groundworks, infrastructure, highways, bulk excavations, land remediation, and stabilisation. 

ECL is a privately owned company, with annual revenue over £100 million and a workforce of more than 1,000. Its business activities are primarily undertaken in the United Kingdom. It is appreciated that whilst the company does not operate outside the UK, its major suppliers do and can source materials and/or manufacture products in a variety of countries round the globe. 

ECL’s Supply Chain include the following:

  • Sourcing of labouring through subcontractors;
  • Recruitment Agencies;
  • Suppliers of goods, services, and materials. 

Definitions 

ECL considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
  • Being dehumanised, treated as a commodity, or being bought or sold as property;
  • Being physically constrained or to have restriction placed on freedom of movement. 

Potential Exposure 

The organisation considers its main exposure to the risk of slavery and human trafficking to exist in our procurement of materials from suppliers who source these from high-risk countries. ECL’s supply chain is intentionally limited to suppliers well known to the organisation, who have demonstrated they meet our standards. 

In general, ECL considers its exposure to slavery/human trafficking as relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services. 

Commitment 

ECL acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. ECL understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally its supply chains. 

ECL does not do business with any organisation, in the UK or elsewhere, that knowingly supports or engages in slavery, servitude, or forced labour.

No labour provided by ECL in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. ECL strictly adheres to the minimum standards in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees. 

It is the responsibility of all our personnel, though particularly those within the Procurement, the Commercial and the Recruitment Departments where supply chain facing and vetting responsibilities are held, to maintain ECL’s duties in respect of the Modern Slavery Act 2015.

Due Diligence

To ensure that no slavery or human trafficking is taking place within our Supply chains, ECL shall:

  • Ensure that all its employees are legally employed and are paid at least the minimum wage and have the right to work;
  • Ensure working conditions are safe and that working hours are not excessive; 
  • Ensure that our sub- contractors are similarly compliant with their staffing; 
  • Include pre-contract checks with all new suppliers and sub- contractors to ensure compliance with this policy;  
  • Use our Suppliers/Subcontractors Pre-Qualification Questionnaire to establish compliance in human resourcing;  
  • Conduct regular audits of existing suppliers and subcontractors;
  • Share knowledge and improve understanding amongst its workforce on the signs to look out for and the mechanism for reporting suspected instances of modern slavery;  
  • Protect Whistle-blowers – our Whistleblowing Policy provides a mechanism for both those who work in and with the organisation to raise concerns without fear of reprisals;  
  • Use our Procurement Team to strengthen supplier engagement and maintain effective links with them, to ensure compliance with the UK Modern Slavery Act 2015 and any relevant Industry and International Standards;  
  • Publish the Modern Slavery Policy on our website for public assess. 

Measuring Effectiveness

ECL uses the following KPIs, to ensure how effective we have been at ensuring slavery and human trafficking is not taking place in any part of our business or supply chains.

 As a result, ECL is committed, as follows:

  • To ensure all employees, deemed relevant, complete training on modern slavery on an annual basis;
  • To maintain a robust supply chain verification process, whereby ECL evaluates potential suppliers before they enter the supply chain;
  • To regularly review its existing supply chains and its suppliers.

Training

All key personnel, especially those directly engaged in ECL’s supply chains, have received comprehensive training to ensure a thorough understanding of the risks associated with modern slavery within our operations and supply networks. 

We are also reviewing our on-site induction programme for all new workers to raise awareness of modern slavery, including key signs to look out for and the process for reporting it. 

We provide training for HR and H&S staff, responsible for overseeing our induction program, to remain vigilant for fraudulent right to work documentation, as this can be an indication of modern slavery. 

All staff are informed of the Modern Slavery Policy, which is also included in new employee inductions. 

All ECL’s Directors have been briefed on the subject. 

Related Policies 

ECL has the following policies which further defines and supports its stance on modern slavery: – Recruitment, Procurement, Grievance, Equality, Antibribery and Whistleblowing policies. 

ECL’s Corporate Social Policy and Suppliers Code of Conduct also contributes to our aim of combatting modern slavery. 

All these policies are available to employees via the Employee Handbook and ECL’s internal intranet.

The ECL Board of Directors have approved this statement policy. 

Date of Approval:  1st Sept 2025.