INTRODUCTION

 
1.1 –  This Policy sets out Cantillon Ltd’s actions to understand and address potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

 
1.2 –  This is the second edition of this Policy and it is written in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Cantillon Ltd’ slavery and human trafficking statement for the 2020/2021 financial year.

 
1.3 –  The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

 

2 RISK AND COMPLIANCE

 
2.1 –  We regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chains.

 
2.2 –  Whilst construction as a whole is considered high-risk; our core business of demolition and associated works are less so. We are a family business with long-standing, close ties with our limited number of specialist subcontractors. However, we recognise that there is always the potential for slavery and human trafficking to occur so we will continue to regularly evaluate our supply chains.

 

3 ORGANISATION AND SUPPLY CHAIN

 
3.1 – This statement covers the activities of Cantillon Ltd:

 
3.1.1 – Cantillon Ltd is an organisation that operates in the Demolition sector of the Construction Industry. Its expertise covers services based around our core business of demolition, including the design and provision of demolition, dismantling and related engineering disciplines, enabling works, piling, structural frame, groundworks, substructure and superstructure elements, asbestos removal, asbestos disposal and asbestos management, and transportation of materials to and from sites.

 
3.2 – The organisation currently operates in the UK only.

 
3.3 – Our supply chain is vetted by various members of the senior management team and is made aware of our expectations with regard to this and other issues. We hold ongoing discussions with them to ensure that their staff are provided with suitable working conditions, a living wage and treated with dignity and respect.

 
3.4 – We undertake responsible sourcing of construction products providing a holistic approach to managing a product from the point at which component materials are mined or harvested, Modern Slavery Policy 2020: Ed2
through manufacture and processing. We understand the risk of potential ethical breaches in the manufacture of some supplies and have taken steps to obtain confirmation of the manufacturing location and ethical policies relating to these.

 
3.5 – During 2019 we undertook a number of audits of specialist subcontractors and suppliers, their policies and procedures to ensure compliance in line with this policy.

 

4 RESPONSIBILITY

 
4.1 – Responsibility for the organisation’s anti-slavery initiatives is as follows:

 

  • Policies: This policy is reviewed annually by the Managing Director and Senior
    Management Team; the processes and procedures updated and reviewed as required. The Managing Director holds responsibility for ensuring that this policy is adhered to.
  • Training: During 2019 all staff, including subcontracted and agency, have received dedicated Modern Slavery Training in addition a general induction on the ethical expectations of our company, awareness of the modern slavery issues. The details of this policy are located within the Employee Handbook, reviewed regularly and available via the company systems.

 
We consult and involve direct and indirect employees to help develop a shared and positive attitude towards ethical responsibilities.

 

5 OTHER RELEVANT POLICIES

 
5.1 – The organisation operates the following policies that support its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

 
5.2 – Whistleblowing & Reporting Policy: The organisation encourages all its workers, business partners and clients to report any concerns related to the direct activities, or the supply chain of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing policy makes it clear that workers can make disclosures without fear of retaliation.

 
5.2.1 – For modern slavery concerns staff are provided with the following information:

 
• The Gangmasters and Labour Abuse Authority on 0800 432 0804
• Modern Slavery Helpline on 0800 0121 700 or at https://www.modernslaveryhelpline.org/report.

 
5.3 – Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour. Modern Slavery Policy 2020: Ed2

 
5.4 – Supply Chain Code of Conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with fairness, dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

 
5.5 – Agency Workers Policy: The organisation uses only reputable employment agencies to source labour and always vets and verifies the practices of any new agency it is using before accepting workers from that agency. Cantillon carries out a desktop audit (PQQ) to verify policies, procedures and systems of the agency, asking for verification of employment terms and conditions.

 

6 MOVING FORWARD

 
6.1 – During 2019, Cantillon became Business Partners of Stronger Together a multi-stakeholder a business-led initiative aiming to reduce modern slavery particularly forced labour, labour trafficking and other hidden third-party exploitation of workers. They provide guidance, training, resources and a network for employers, labour providers, workers and their representatives to
work together to reduce exploitation.

 
6.2 – Stronger Together offer a range of in-depth, specialist training opportunities on tackling modern slavery including open workshops, e-learning modules and bespoke in-house training. Working with Stronger Together, Cantillon has been able to offer more detailed training for our employees, agency and subcontractor teams. We will continue working with them throughout 2020 to further enhance our position and understanding of these issues.

 

7 REVIEW

 
7.1 – This Policy will be reviewed annually by the senior management team and authorised by the

Accreditations