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.
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.
3.1 Our supply chains include:
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
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:
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:
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:
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:
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 2021.
Jaysam Contractors Ltd