modern slavery

 Statement of Intent

Fenton Civil Engineering Limited (FCEL hereafter) acknowledges the provisions of the Modern Slavery Act 2015 and will ensure transparency within its organisation and with suppliers of goods and services to the organisation. FCEL is satisfied, from its own due diligence, there is no evidence of any act of modern day slavery or human trafficking within its own organisation.

 Overview

Slavery, forced labour, servitude, and human trafficking are types of ‘Modern Slavery’ – criminal activity that deprives victims of their liberty and usually involves financial and other exploitation.

FCEL conducts business fairly, ethically and with respect to fundamental human rights. We recognise that we have a responsibility to take a robust approach, and are committed, to the prevention of all forms of Modern Slavery, both in our business and in our supply chains.

This FCEL policy applies to employees at all levels, directors, officers, temporary agency workers, seconded workers, volunteers, agents, suppliers, contractors, external consultants, third party representatives, and business partners.

Failure of an employee to comply with this policy may result in disciplinary action, including dismissal.  Failure of a supplier to comply may result in termination of the contract between them and us. It could also involve other legal steps being taken against them.

This policy does not form part of any employee’s contract of employment, and we may review and amend this policy at any time. It will be reviewed on a regular basis to ensure it complies with relevant UK legislation.

 Preventing Modern Slavery in our business

We carry out appropriate checks on all employees, and use reputable recruitment agencies and suppliers, so that we know who is working for us or on our behalf.

We give every employee a written employment contract, and he or she is paid in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks and holidays.

Our senior management will support anyone who raises genuine concerns in good faith under this policy, even if turns out they have been mistaken.  All concerns raised by employees will be taken seriously, investigated and escalated as appropriate and any required action taken without undue delay.

 What we expect of our Suppliers

While we cannot control the conduct of others, we are very clear about our expectation that any of our direct subcontractors or suppliers should have thorough, up-to-date policies and mechanisms in place to deal with modern slavery. This expectation extends, naturally, through our direct subcontractors and suppliers to those in the supply chain whom they deal with.

Therefore, if you are part of our supply chain, we ask that you comply with your legal obligations in relation to Modern Slavery and implement due diligence for your own suppliers and subcontractors to ensure there is no slavery or human trafficking in their supply chain.

By conducting the vast majority of our business with UK suppliers, we minimise the possibility of inadvertently working with someone in the supply chain who may be at higher risk of involvement (deliberately or not) in Modern Slavery.

If, as our supplier or subcontractor, you are found to have Modern Slavery in your business, or knowingly in your supply chain, we may terminate our contract with you and pursue legal remedies against you.

 For an Employee or a Worker providing services for us

We ensure, without fail, that each and every one of our employees have the requisite documents granting them the legal Right to Work in the UK.

Trust is vital in identifying Modern Slavery, which is why our process for highlighting concerns regarding the issue is highly confidential. This enables people to feel free to speak up, knowing they will remain anonymous, and that their concerns will be dealt with in the strictest confidence.

As an employee or worker providing services for us, we expect you to immediately report any suspicions of Modern Slavery in our business or supply chains to our Managing Director who will investigate and produce a report within a reasonable time, on actions which may require to be taken.

In line with FCEL’s Whistle Blowing Policy, you will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies even if, after investigation, they are found to be mistaken.  If you believe that you have suffered any such treatment, you should immediately tell our Managing Director and, if you are an employee, refer to our Grievance and Whistleblowing Policies.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Fenton Civils’ Modern Slavery and Human Trafficking Policy for the 12 months following its last review / revision.

Last Reviewed / Revised January 2025