Modern Slavery Policy - 2020 Approved by – Sean Hoare, Managing Director

Self-delivering civil engineering for the homes and businesses of tomorrow

Modern Slavery Policy

This statement is made pursuant to S.54 of the Modern Slavery Act 2015 and sets out the steps that ECL Civil Engineering Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. ECL Civil Engineering Ltd has a zero-tolerance approach to any form of modern slavery.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

This statement applies to the whole of the ECL Civil Engineering Ltd Company

Areas of the business that are considered to be high risk, such as the appointment of subcontractors and our supply chain, are regularly reviewed and assessed to ensure that any potential gaps or new risks are identified. Weekly management meetings are used to consider any additional steps that may be required to mitigate these risks.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.

2. Recruitment policy. We operate a robust recruitment policy, including conducting

eligibility to work in the UK checks for all employees to safeguard against human

trafficking or individuals being forced to work against their will.

3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Our suppliers

ECL Civil Engineering Ltd operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier.

This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions.

Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

Modern Slavery Policy – 2020 Approved by – Sean Hoare, Managing Director

Self-delivering civil engineering for the homes and businesses of tomorrow Page 2 of 2

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have taken steps to eradicate modern slavery within their business

2. They hold their own suppliers to account over modern slavery

3. They pay their employees at least the national minimum wage.

4. We may terminate the contract at any time should any instances of modern slavery

come to light

Training

We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

No reports are received from employees, the public, or law enforcement agencies to

indicate that modern slavery practices have been identified.

Signed:- Date:- 03/01/2020

Sean Hoare, Managing Director