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.
The information included in this statement refers to the financial year ending June 2022.
ECL’s organisational structure, business and supply chains
ECL is a leading civil engineering and groundworks company operating within the housing construction sector, mainly in the counties of Bedfordshire and Northamptonshire. 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 an annual turnover in excess of £120 million and a workforce of over 1000. 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.
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.
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.
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 enter into business with any organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory 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.
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/Sub Contractors 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.
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, the
Organisation 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
All key personnel, particularly those involved directly in supply chains within ECL, have been trained to a high level of understanding of the risks of modern slavery in our supply chain and business.
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 ECL’s Directors have been briefed on the subject.
The Modern Slavery Policy has been communicated for all staff to read, and new staff are introduced to this policy as part of their induction.
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 of 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 July 2022.