Modern Slavery Policy

Scope

All employees of the AEG Construction Group, together with any individual or organisation that works for or with the Company.

Policy

This Policy should be read in conjunction with our Modern Slavery Act Transparency Statement. Modern slavery encompasses slavery, servitude, human trafficking and forced labour and is a crime resulting in an abhorrent abuse of human rights.

AEG Construction 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.
We will put effective systems and controls in place to safeguard against modern slavery in any part of our business or supply chains.
We expect suppliers and sub-contractors to hold themselves and their own supply chains to the same high standards.

Tackling modern slavery protects vulnerable workers and helps prevent and remedy human rights violations. It can also bring business benefits including enhanced reputation, customer growth, staff retention and stronger, more resilient supply chains.

Everyone who works for the Company has a responsibility to prevent and identify modern slavery and must avoid any activity contrary to this Policy. We expect those who work for and with the Company to raise concerns promptly if they suspect actual or potential issues.

The aims of this policy are to

Provide guidance with regard to identifying modern slavery.
Explain measures the Company is taking to prevent, identify and reduce risk in business and supply chains.
Encourage prompt reporting of suspected potential or actual modern slavery (confidentiality respected; concerns investigated as appropriate).
Provide guidance on how to raise concerns.
Reassure individuals they can raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

Identifying Modern Slavery – Definitions

Slavery

The condition in which a person is owned as property by another who has absolute power over that person. Since legal “ownership” is not possible, the key element is behaviour as if the person were owned, depriving the victim of freedom.

Servitude

The obligation to provide services imposed by coercion, including living on another person’s property and the impossibility of changing condition.

Forced or Compulsory Labour

Work or service exacted under the menace of any penalty where the person has not offered themselves voluntarily. Coercion may be direct or subtle.

Human Trafficking

Offence committed where a person arranges or facilitates the travel of another person with a view to exploitation. The offence can be committed even where the victim consents, and exploitation does not need to have taken place for the offence to be committed.

Responsibilities

Board of Directors

Uphold the Policy in letter and spirit at all times.
Ensure guidance and training is provided to employees as appropriate.
Review effectiveness of the Policy and actions taken in response to concerns raised.

Directors, Managers & Supervisors

Implement and promote the Policy.
Ensure staff are aware of responsibilities under the Policy.
Assist individuals to use the Whistleblowing Policy where a concern falls within scope.

Procurement Department

Implement measures to prevent, identify, assess and reduce risk of modern slavery in supply chains.

All Employees

Comply with the letter and spirit of this Policy.
Raise concerns promptly where they fall within scope.

Others

Given access to this Policy (e.g., prospective employees, partners, agency workers, customers, suppliers, sub-contractors).
Made aware of expected standards of behaviour for anyone working for or with the Company.

Modern Slavery Act Transparency Statement

Our current Modern Slavery Transparency Statement sets out the steps undertaken and planned during the financial year to ensure that modern slavery or human trafficking is not taking place in any of our supply chains and in any part of our own business.

This statement is published on our external Company website.

Raising a concern

Concerns regarding actual or potential modern slavery should be raised using the procedure set out in the Company’s Whistleblowing Policy.
Concerns will be taken seriously, investigated as appropriate and confidentiality will be respected.
If the concern relates to a third party (e.g., supplier/sub-contractor), the law may allow raising the concern with that third party; however, internal reporting is encouraged first.
If uncertain whether an issue constitutes modern slavery, seek guidance from your manager or the Whistleblowing Officer.
The Modern Slavery Helpline can also provide information and guidance (see Contacts).

Protection and support for individuals who raise a concern

The Company will protect and support individuals who raise genuine concerns under the Whistleblowing Policy, even if they turn out to be mistaken.
Individuals will not suffer detrimental treatment as a result of raising a concern under the Whistleblowing Policy.
The Company will also protect individuals from any detriment caused by or on behalf of aggrieved employees or other individuals.
If you believe you have suffered detriment after raising a concern, inform the Whistleblowing Officer immediately.

Further information is available from the Whistleblowing Policy.

Measures to prevent, identify, assess and reduce risk

Communicate our zero-tolerance approach to all employees and anyone who works for or with the Company.
Carry out risk assessments of suppliers and sub-contractors.
Assess identified risks with existing and new suppliers/sub-contractors and take appropriate action in line with the Modern Slavery Act principles.
Provide relevant training to employees on signs of modern slavery and measures to prevent or minimise risk.
Use only reputable employment or recruitment agencies to source agency workers.
Carry out appropriate identity checks in accordance with our Prevention of Illegal Working Policy to ensure new employees are eligible to work in the UK.

This Policy does not form part of any employee’s or self-employed partner’s contract and may be amended by the Company from time to time. The Company may also vary procedures (including time limits) as appropriate.