Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (‘the Act’) and constitutes XYZ Rail & Civils slavery and human trafficking statement for the financial year ending 28 February 2020.

This statement has been approved by the and signed by Kirk Taylor, the Managing Director of XYZ Rail & Civils. Information contained in this statement is correct to the date of publish.

About Us

XYZ Rail & Civils is a leading provider of innovation and efficient rail and non-rail civil engineering projects in the UK, trusted to deliver throughout the industry thanks to our attention to detail and pride in our services. As at the end of the financial year to 28 February 2020, XYZ Rail & Civils has over 188 employees

Policies

XYZ Rail & Civils is committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.

The company’s internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to
ensure slavery and human trafficking is not taking place anywhere in our supply chains.

All internal policies are reviewed regularly to ensure they are appropriate, well communicated and promote continued compliance with the Act and other applicable legislation.

XYZ Rail & Civils has in place the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

Corporate Social Responsibility Policy. This policy is designed to ensure that XYZ Rail & Civils conducts all business responsibly and with the highest ethical and professional standards.

Whistleblowing Policy. XYZ Rail & Civils encourage all employees to report any concerns related to the activities of the business, including any worries in relation to slavery and human trafficking. The Whistleblowing Policy and procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially.

Equality, Diversity & Inclusion Policy. XYZ Rail & Civils is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination, harassment and victimisation on the grounds of race, sex, pregnancy, maternity, martial or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

Ethics & Business Integrity Policy. This policy outlines XYZ Rail & Civils requirements for conducting business to the highest ethical standards. The Company demonstrates a clear approach to business integrity and ethics, which underlies Company values.

Recruitment Policy. XYZ Rail & Civils ensures that the process of recruiting employees is fair, consistent, professional, and non-discriminatory to both internal and external candidates.

Our commitment – what we do

SUPPLY CHAIN ADHERENCE TO THE XYZ VALUES AND ETHICS

XYZ Rail & Civils considers its supply chain to be at a ‘low risk’ in relation to modern slavery and human trafficking. Given the nature of the business and the sectors within which we work, there is no significant utilisation of overseas or unskilled labour, being key areas identified as posing a higher risk; imports are of a minimal amount, unskilled labour is of a small quantity and operations are UK based meaning suppliers are already under an obligation to comply with UK law on forced labour.

SUPPLIER ADHERENCE

XYZ Rail & Civils demonstrates a zero tolerance to slavery and human trafficking and reserves its rights to terminate any arrangements with any of its suppliers should any modern slavery or human trafficking offence be committed or suspected.

XYZ Rail & Civils will update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.

EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

Any suspected incidence of slavery or human trafficking within XYZ Rail & Civils or its supply chain would be immediately reported to the Board of Directors in the first instance. It would then be dealt with appropriately, which may include, but is not limited to, terminating commercial relationships, disciplinary action and notifying the relevant authorities.

WHAT WE HAVE DONE IN 2019/2020

In 2019/2020, XYZ Rail & Civils took the following action:

• Employee training was rolled out via e-learning, one on one workshops and as part of all new starter inductions.
• All new employees are subject to pre-employment checks to ensure their right to work in the UK, and to confirm their identity.
• We have adopted a Zero Tolerance to modern day slavery and human trafficking and will not knowingly support or deal with any business, supplier or organisation involved in slavery or human trafficking.
• We have committed to promptly and thoroughly investigate any claims or indications that a supplier of goods or services to the business is engaging in human trafficking or slave labour or is otherwise not complying with the requirements of its policy.
• Improved new supplier approval processes, ensure a dedicated section was included, to assess any modern slavery or human trafficking risks, with new suppliers and included these reviews as part of continuing assessment of our supply chain
• Remaining suppliers were written to with a briefing identifying our expectations of our suppliers and consequences should any modern slavery or human trafficking offences be committed or suspected

WHAT WE WILL DO IN 2020/2021

As part of our on-going commitment to ensuring modern slavery is not present within the Company, we will look to take the following action in 2020/2021:

• Continue to raise awareness amongst employees of modern slavery issues to ensure that employees are aware of the requirements of our commitment and policy. e.g. contract provisions and supplier assessments; by providing training and awareness as appropriate throughout the coming year.
• Further review of our supplier approval process, full suite of precedent contracts and terms to ensure all clients, customers, supply chain, partners and stakeholders that we contract with, as applicable, are required to adhere to our relevant policies.
• Develop an expanded third-party due diligence process to apply to strategic opportunities across XYZ Rail & Civils to foster a standardised and consistent approach to modern slavery and human trafficking compliance.

Overall, XYZ Rail & Civils will continue to focus on understanding further our supply chains, identifying risk areas, and increasing awareness amongst employees on the issues of modern slavery and the reporting procedures available to them. We will continue to update policies and procedures as required to ensure appropriate safeguards against any mistreatment of persons are in place.

Kirk Taylor
Managing Director
XYZ Rail Ltd
January 2021