Statement for financial year ending January 2019
1.1 This statement is made pursuant to s.54 of the Modern Slavery Act 2015 (‘MSA’). This statement sets out the steps which our organisation has undertaken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
1.2 Jaysam Contractors Ltd (‘JCL’) and its associated companies are committed to the principles and aims of the MSA and we wish to improve our practices in order to achieve this.
1.3 The aim of the MSA is in line with our own principles of respect for the individual, integrity, and striving for excellence in all that we undertake. We recognise the importance of any measures which seek to bring about greater transparency and scrutiny of our various supply chains in order to combat slavery and trafficking activities. In accordance with the legislation, this statement will give information about the introduction of various measures throughout our supply chain network, which will be most effective at reducing the risk of slavery and trafficking activities being present within our business operations.
1.4 We look forward to working with our partners, contractors and suppliers to bring any necessary changes into effect, and then to review over the next 12 months their effectiveness and consider any changes or additional measures which may increase the robustness of our policies. We are committed to improving our practices through these initial activities, and through improvements identified in future years, to combatting slavery and human trafficking.
Organisational Structure and Business
2.1 JCL is a company based in Wealdstone, Middlesex, in north west London. It was established over 25 years ago and specialises in fitting out properties, both commercial and residential. It has particular experience in the retail sector and proudly counts many well known high street names among its clients. The company directly employs approximately 60 staff based at its headquarters in London. In addition to these staff, JCL uses the services of many contractors who are usually engaged via agencies.
2.2 The company has a turnover over £36 million and it solely operates in the UK.
2.3 This statement addresses the measures put into place by JCL and its associated companies.
Our associated companies comprise a number of development companies and joint venture companies, some of which do not exceed the £36m annual turnover threshold in their own right. However, JCL is looking to embed best practice in all of its operations. This statement and the accompanying Anti-Slavery Policy will therefore apply equally to all of these companies.
Our Supply Chains
3.1 Our supply chains include:
- Consultants and advisers
- Contractors and sub-contractors (some of which provide labour)
- Staff agency companies
- Suppliers of goods, supplies and materials for building projects, IT hardware and software
3.2 We have identified the following areas of the supply chain as comprising the highest risk of slavery and trafficking activities:
Human trafficking – in circumstances when using sub-contracted labour forces or supplied agency workers on our sites
Slavery – In circumstances when importing building materials from countries with poor records on slavery and human trafficking
Our Policies on Slavery and Human Trafficking
4.1 We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. The practical measures we will be taking throughout our operations are reflected throughout this statement and our Anti-Slavery Policy, and will be built upon and developed throughout the coming years to incorporate best practice into our operations.
4.2 In addition we operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:
- Equal opportunities policy, which includes our recruitment and selection processes.
- In respect of recruitment, we conduct eligibility to work in the UK checks for all employees. This helps to safeguard against human trafficking and individuals being forced to work against their will. We also request these checks are done by the main agencies we use, and copies of those checks are sent to us to review and keep.
- Anti-harrassment and bullying policy
- Anti-corruption and bribery policy
- Whistleblowing policy
- In the forthcoming 12 months we shall be reviewing our policies and will be considering if they require amending to make them more effective. We will report back on this review next year.
- Health and safety policy. This sets out the expectations on employees and contractors to support our efforts to provide a safe and healthy workplace and to meet their own individual duty of care to others.
Due Diligence Processes and Supplier Adherence
5.1 We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, we have in place a strategy to identify and mitigate risk. We will be carrying out the following activities during 2019 and beyond:
Contacting existing suppliers and sub-contractors to ask them to confirm their adherence to our Anti-Slavery Policy.
Ensuring that significant new suppliers and sub-contractors undertake to comply with our Anti-Slavery Policy through use of due diligence questionnaires and relevant contractual provisions, with appropriate termination provisions for failure to comply.
Ensuring that the high-risk areas as identified under paragraph 3.2 are kept under regular review to determine whether additional and/or targeted measures are required within our supply chain to combat the risk of slavery and trafficking.
Ensuring that our whistleblowing procedure is drafted sufficiently widely to encourage whistleblowing in relation to any identified breaches of our Anti-Slavery Policy. We will further promote this policy among staff reiterating its role in reporting instances of suspected modern slavery or human trafficking throughout any part of our operation.
5.2 These systems have been put in place to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistleblowers.
5.3 All of our sub-contractors are either UK entities or are UK offices of large international companies. The majority of the goods we buy are produced either in the UK or in jurisdictions that have established frameworks against slavery and human trafficking.
6.1 The personnel responsible for compliance with this statement and the Anti-Slavery Policy, and for updating and improving our procedures in forthcoming years, shall consist of involvement from the following departments:
- Human resources
- Management Services
7.1 To ensure a good understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we shall be implementing training measures for all of our senior staff and for those site managers who are based at the various different projects which the company is engaged on. Our site managers are employed by us and are best placed to have day to day contact with contractors and our other main suppliers. They have a direct link back to management who are based at our main office.
7.2 The training will be designed to highlight the requirements of the Act and our Anti-Slavery Policy, and its practical application within our business.
8.1 We will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Create a register of the staff agencies we use and also of all our main sub-contractors
- 60% of existing sub-contractors and suppliers on our approved register to commit to our updated due diligence questionnaire confirming their compliance with our Anti-Slavery Policy
- 100% of new sub-contractors and core suppliers to confirm via our due diligence questionnaire that they will comply with our Anti-Slavery Policy
- 100% of new supplier and sub-contractor contracts to contain provisions requiring compliance with our Anti-Slavery Policy
9.1 This statement and the Anti-Slavery Policy will be subject to regular and ongoing reviews to ensure its effectiveness, and to update the requirements where further measures are identified.
This statement was approved by the Board of Directors on 27th February 2019.
Jaysam Contractors Ltd