Modern slavery and human trafficking (Modern Slavery Act 2015) is a serious global issue that continues to affect millions of people from around the world, including many in developed countries, who are kept and exploited in various forms of slavery. Construction Testing Solutions Ltd (CTS) recognises the importance of our role in eradicating this issue within the construction supply chain and has a zero-tolerance approach to all forms of modern slavery.
CTS have taken several steps to identify any form of modern slavery, which are outlined in this policy, along with the actions being taken to continue to educate our employees and to identify any potential modern slavery risks related to our business.
It is important to CTS that everyone working for the company or within its supply chain can expect adequate working conditions, can work of their own free will and expect fair pay in return.
Our business activities
CTS operates several UKAS accredited construction materials testing laboratories throughout the United Kingdom, covering a wide range of laboratory and on-site testing and inspection activities, structural investigation, calibration services and geotechnical and environmental consultancy services for our construction and civil engineering clients.
Our supply chain
These activities typically fall into two categories:
- Suppliers – equipment and consumable manufacturers and suppliers registered and operating within the United Kingdom, with the necessary experience, skills, and qualifications to provide us with laboratory and site testing equipment that comply with British and European test standards
- Subcontractors – such as other UKAS accredited laboratories that can provide services that we do not hold accreditation for ourselves or individuals or organisations that provide specialist services that support our work on site for our clients.
Our head office
Based in Castle Donington, the head office currently includes central support functions including Corporate Governance, HR, H&S, Marketing, Finance, and IT.
Our supply chain for central services is typically UK based, providing support functions and facilities, such as technology, professional and standard operating systems support to assist the company in day-to-day operational management.
Our HR and recruitment processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to protect employees from any mistreatment or coercion.
CTS continues to operate robust HR processes using technology from Team Tailor and Cascade, to select the best quality staff and provide effective support for staff while they work for us.
All our employees enter into a contract of employment which they are free to terminate following the appropriate notice periods as defined in the contract.
We have continued to promote a culture of wellbeing, openness, support, and responsibility including:
- Updating all computer hardware to support the use of Microsoft Teams helping us stay in contact with and support staff who are home working
- Providing EAP services through Westfield Health
- Continuing to offer staff access to support from our in-house wellbeing ambassadors which are MHFA trained supporting each site and department. We run awareness campaigns and activities regularly throughout the year and we also have details of these for colleagues on wellbeing notice boards, on posters at site and on our systems. We also run engagement surveys throughout the year to understand where, as a business we can improve.
Training and awareness
A number of training and awareness initiatives have been completed over the last 12 months including:
- Mental Health Awareness training for all managers
- A number of communications issued through CTS News directly to staff to help support their mental health during lockdown. The company also used a combination of pigeonhole drops, posters and letters sent to homes and introduced all hands calls for monthly company updates from the CEO. Our wellbeing ambassadors are also available to create awareness and to check in on colleagues
- Reinforcement of our own Whistleblowing policy to all staff
- Issuing a Modern Slavery Awareness bulletin to all staff highlighting key indicators and signposting to the GLAA (Gangmasters and Labour Abuse Authority) for additional advice and support.
Supply chain process
At times CTS will use subcontractors to carry out work on our behalf who fall under two categories, suppliers of test equipment and other consumables, or suppliers of other testing or calibration services that we cannot conduct ourselves. A review of our supplier management process is planned for 2021.
Supply chain survey results
All our supply chain were surveyed to ascertain their understanding and compliance with the Modern Slavery Act. Results from a total of 173 responses indicate that:
- No company within our supply chain has been convicted of breaching MSA 2015 or had notice served on them
- 69% of our suppliers have a documented MSA Policy
- 96% of our supply chain who have a documented policy told us their policy prohibits the use of a supplier or subcontractor who has committed an offence against the MSA 2015
- 59% of our supply chain have a documented whistleblowing policy
- 25% of our suppliers do not use suppliers or subcontractors
KPI’s and looking ahead
CTS has undertaken a commitment over the next 12 months to continue to develop policies, procedures, and activities to combat slavery and human trafficking within our business and supply chain. Our objectives and commitments include:
- To continue to monitor and improve our policies and procedures to ensure our standards are being maintained and that we remain compliant with all legal, statutory and customer requirements.
- To implement our Supply Chain Evaluation and Approval processes throughout the whole company to verify compliance with the Act, details of their approach to modern slavery, and establishing any risks from the whole supply chain.
- To continue to train our managers and raise their awareness and understanding of the Modern Slavery act. To provide them with the skills required to monitor changes within our supply chain and the external environment in order to update our approach accordingly, and to ensure that the risk within our supply chain remains low and all such practices are eliminated from CTS and our associated supply chain.
- To continue to provide our senior management team, operational managers, and supervisors training in Modern Slavery to enable them to recognise the types of modern slavery, and how these and human trafficking can directly affect our business.
- To continue to communicate to all employees the CTS position and approach to the Act through our CTS News platform, all hands monthly calls, and notice board updates
- To continue to promote our Whistleblowing Policy and provide staff with a means of confidentially speaking up if they suspect that they, or their colleagues, may be subject to abuse of the act.
- To continue to build upon the excellent work promoting mental health and supporting our Mental Health First Aiders and Champions, led by the senior management team, recognising that mental wellbeing, as well as physical safety are critical to eliminating exploitation, removing threats and abuse.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Construction Testing Solutions Limited slavery and human trafficking statement for the financial year ended 31 March 2021
Chief Executive Officer
6th January 2021