Modern Slavery Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by SPIE UK Limited and all its subsidiaries (“SPIE UK”) during the financial year ending 31 December 2018 to prevent modern slavery and human trafficking in its business operations and supply chain.
This is the fourth SPIE UK Modern Slavery statement, during the past year we have continued to develop our understanding of risk and we have put effective responses in place to minimise that risk.
This statement sets out SPIE UK’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking within our business and our supply chains.
In 2017, a report published by the International Labour Organisation (ILO) in collaboration with the Walk Free Foundation, identified that, at any given time in 2016, an estimated 40.3 million people were in modern slavery, including 24.9 million in forced labour.
Out of the 24.9 million people trapped in forced labour, an estimated 16 million are in forced labour in the private economy including sectors such as construction and manufacturing.
In the UK last year, 5,143 potential victims of trafficking and slavery were flagged up to the National Referral Mechanism, which identifies and supports victims. This was the highest number recorded by the UK authorities since the figures were first compiled in 2009 - and a 35% rise from 2016.
SPIE UK is a subsidiary of the SPIE group, the independent European leader in multi-technical services in the areas of energy and communications. It provides energy, safety and environmentally focused solutions across multi-technical and support services from initial design, through installation, testing, commissioning to long term maintenance and facilities management.
As a company predominantly offering Engineering Services, our supply chain is characterised by skilled technical contractors and trades. We have in excess of 6,500 suppliers and subcontractors supporting our UK business predominantly (99.5%) based in the UK. Of our direct spend in 2018, no spend was spent with suppliers in high risk countries of origin (such countries being determined as high risk by the Global Slavery Index).
SPIE UK is absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensuring our supply chains are free from slavery and human trafficking.
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures which are designed to:
• Establish and assess areas of potential risk in our business and supply chains
• Monitor potential risk areas in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains
• Provide adequate protection for whistleblowers
We are committed to ensuring that our suppliers and subcontractors, of which we have over 4,700, adhere to the highest standards of ethics. As such, they are required to sign the SPIE UK “Charter for Suppliers and Subcontractors of SPIE” as part of our due diligence process. The SPIE Supplier Charter states
that suppliers and subcontractors must not use any kind of forced or compulsory labour as defined by Conventions C29 of 1930 and C105 of 1957 of the ILO (International Labour Organisation). Forced or compulsory labour means all work or service exacted from any person under the menace of any penalty and for which said person has not offered him/herself voluntarily (deemed to include human trafficking and modern slavery).
Within the Charter, SPIE UK also expects its suppliers and subcontractors to implement the necessary procedures to ensure that these principles are conveyed to their own suppliers and subcontractors. Any serious or deliberate failure by a supplier or subcontractor to observe the principles set out in the Charter may lead to their exclusion from our approved supplier list.
Relevant internal documents
SPIE UK operates the following policies that highlight our commitment to the identification and prevention of unethical activities within our organisation (including human trafficking and modern slavery): Whistleblowing policy – SPIE UK encourages all its employees and other workers engaged through third party arrangements to confidentially report any concerns of unethical or illegal conduct within the organisation. This is deemed to include any circumstances that may give rise to an increased risk of human trafficking or modern slavery.
There is a 24/7 confidential hotline which enables employees, contractors and suppliers to report issues relating to their working environment in a safe and secure way. Principles of Business Ethical Conduct – this is a SPIE Group policy that applies across the whole of SPIE and all SPIE UK employees and workers are required to agree to comply with this code of ethical conduct on joining the organisation.
This code states “SPIE complies strictly with human right laws prohibiting child labour and forced labour, any form of discrimination and the use of any illicit work” (deemed to include human trafficking and modern slavery). Any instances of non-compliance will be investigated and subject to disciplinary action where necessary.
Further highlighting our commitment to the prevention of unethical business conduct, SPIE UK operates an internal Ethics Committee, consisting of the Chief Executive Officer, Finance Director and Legal Director & Company Secretary. The committee would be informed in the event of any concerns of human trafficking or modern slavery risks.
In 2003, SPIE Group pledged to support the United Nations Global Compact, which asks companies to embrace, support and enact, within their sphere of influence a set of core values in the areas of human rights, labour standards, the environment and anti-corruption.
Risk assessment and management
SPIE undertake CSR assessments of our supply chain using the 3rd party body Eco Vardis. Eco Vardis provide scorecards which include scoring for fair Labour and Human Rights; this forms the basis for SPIE’s risk management. A score of less than 30% is considered unacceptable and would place the supplier under consideration for removal as an approved supplier to the business. When considering a new company to join the SPIE Approved Supplier List, each business must sign SPIE’s Supplier Charter. The Charter contains a statement enforcing that all suppliers agree to abide by the guidelines stipulated by the Modern Slavery Act. Failure to sign the Charter results in a block to approval.As part of SPIE’s standard Terms and Conditions reference is made to compliance to the Modern Slavery Act. Failure to accept these terms is also grounds for contract review.
During the financial year 1 January 2018 to 31 December 2018 we have carried out Business Ethics training, delivered by SPIE Legal Director.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and constitutes SPIE UK’s slavery and human trafficking statement for the financial year 1 January 2018 to 31 December 2018.
This statement was approved by the Board of Directors and signed by Rob Goodhew, CEO for SPIE UK, on 11th April 2019.
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