Modern Slavery & Human Trafficking Policy Statement

This document contains Wynne Construction's policy on modern slavery and human trafficking and its statement under Section 54 of the Modern Slavery Act 2015.

Policy
Forced or compulsory labour, human trafficking and other kinds of slavery represent some of most serious forms of human rights abuse in society. Wynne Construction is fundamentally opposed to slavery, human trafficking, forced labour, the sale or exploitation of children and all exploitative practices in the workplace. We acknowledge our duties and responsibilities under Section 54 of the Modern Slavery Act 2015 and are therefore committed to conducting all aspects of our business in an ethical and transparent manner. We require that all workers are treated with dignity and respect and that all our subcontractors and suppliers do not engage in any practices involving slavery, human trafficking, forced labour, the sale or exploitation of children or any exploitative practices in the workplace, and furthermore that they do not knowingly themselves contract with third parties which do. Wynne Construction will terminate business relationships with any contractor or supplier found to be in breach of anti-slavery and human trafficking obligations.

Our Business
Wynne Construction, the trading name of C Wynne & Sons Ltd, is a North Wales based construction company operating throughout Wales and in the North West of England. Our company provides construction and related services across a variety of market sectors including education, healthcare, sport and leisure, public and civil buildings/amenities, Industry, retail and commerce. Our clients include public and private clients such as local authorities, NHS Trusts, universities and colleges. We are a principal contractor and have approximately 50 direct employees who work alongside large numbers of subcontractors from our robust yet ever evolving network of highly qualified and competent supply chain partners. We also source products from our network of supply chain manufacturers.

Assessing and Managing Risk
We acknowledge that there is a risk of modern slavery and human trafficking occurring within any aspect of our business operations, whether in relation to direct employment, use of sub-contractors or the supply of materials and that we have a responsibility to be alert to the risks in both Wynne Construction's business and in our supply chain. In assessing and managing the risks, we:

• have developed a policy confirming our zero tolerance of modern slavery and human trafficking
• require that our sub-contractors and suppliers acknowledge their responsibility for adhering to our policies
• have undertaken risk assessments including an organisational SWOT analysis to identify the key procurement risks categories in our supply chain and review those risk assessments regularly
• have incorporated obligations into our standard contractual terms for our sub-contractors and suppliers to comply with our policies, including our Modern Slavery and Human Trafficking policy
• undertake checks on new recruits to ensure that they are eligible to work in the UK
• continue to monitor the effectiveness of our actions against the risk of modern slavery and human trafficking. This includes reviewing our policies and our procurement standards and making necessary changes
• provide training to key employees on the risks of modern slavery and human trafficking and our processes to mitigate these
• undertake audits of key supply chain partners to understand and validate the controls in their organisations and provide an opportunity to learn from best practice. Where issues are identified (including through our audit process) that are not resolved to our satisfaction, we review the on-going nature of the relationship with that relevant organisation.

Employer Responsibilities
As an employer we take the welfare of our employees seriously and are committed to providing all employees with good and fair working conditions. We comply with minimum age and wage laws and do not employ child labour. All our employees are paid directly by bank transfer and never via third party bank accounts, thus minimising the risk of forced or compulsory labour. Employees from overseas are vetted for the right to work in the UK and where employees require a work permit/VISA we ensure they have the necessary documentation in place. Our Whistleblowing policy is designed to protect our employees and encourage them to report wrongdoing (including exploitation) in any form.

Supply Chain Management Responsibilities
As principal contractor we work in partnership with a large number of sub-contractors and other suppliers to fulfil our commercial and contractual obligations to our customers. Like many companies operating in the construction industry, our supply chain can be complex as there can often be several tiers of suppliers between us (as the main contractor) and the source of the raw materials and labour we use. Consequently, we have developed procedures to ensure that both our existing and potential supply chain partners (both subcontractors and suppliers) understand our values, standards and requirements regarding the prevention of modern slavery and human trafficking within supply chains. As part of our sub-contractor approval and due diligence procedures, new sub-contractors and suppliers are required to sign up to our "TASC Supply Chain Commitment Charter".

- Click here to view our TASC Supply Chain Charter - February 2023

We have also signed up to the Welsh Government’s Code of Practice on Ethical Employment in Supply Chains through the TISCreport. By signing up to the Code, we agree to comply with the 12 commitments which are designed to eliminate modern slavery and support ethical employment practices. The Welsh Government online Code of Practice Tracker enables us to monitor our progress in fulfilling these commitments.

Awareness
As part of our commitment to the prevention of modern slavery and human trafficking and to ensure that we conduct our business in an ethical and transparent manner we include awareness of modern slavery in our inductions and in annual refresher training for all staff.

Training
Key employees within the Company (including those working in supply chain, procurement, human resources, health & safety and senior on-site roles) are given training on modern slavery and human trafficking which covers the requirements of the Modern Slavery Act 2015, Wynne Construction's obligations, our requirements for supply chain partners and the potential consequences for non-compliance.

Our Policies
We are committed to acting ethically and with integrity in all our business dealings and relationships and to maintaining systems and controls designed to ensure modern slavery and human trafficking are not taking place in our business or within our supply chain. To this end we have a number of policies that are designed to identify risks and prevent occurrences of, modern slavery and human trafficking in our operations.

These include our:

• Anti-Slavery & Human Trafficking Policy
• Equal Opportunities Policy
• Ethical Trading Policy
• Illegal Workers Policy
• TASC Supply Chain Charter
• Health & Safety Policy
• Anti-Harassment & Bullying Policy
• Grievance Procedure
• Anti-Corruption and Bribery Policy
• Employee Code of Conduct/Handbook
• Whistleblowing Policy
• Social Value Policy

Ongoing review
We monitor the effectiveness of our actions against modern slavery and human trafficking and continue to review and evolve our anti-slavery and human trafficking policies and procedures, keeping our pre-qualification standards for the appointment of new suppliers and subcontractors under review, ensuring relevant employees continue to receive appropriate training on identifying any potential unlawful or unethical conduct within our operations and supply chain.

Compliance
Failure to comply with the Act, and/or this policy statement will be deemed to be a material breach of the terms of our standard commercial agreements and contracts of employment. This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015 and constitutes Wynne Construction's Modern Slavery and Human Trafficking statement for the financial year 31 July 2020.

It was approved by the Senior Management of C Wynne & Sons Ltd on 21 December 2020.

Signed by:  

Chris Wynne
Managing Director
For and on behalf of C Wynne & Sons Ltd