Modern Slavery Act 2015
Modern Slavery Statement 2019
This statement has been approved by the VGC Group board of directors. It is published in accordance with the Modern Slavery Act 2015. The hard copy was signed by Laurence Mckidd, managing director. It will be reviewed annually (next review October 2020).
Structure, business and supply chains
VGC provides skilled people and deliver quality civil engineering projects to the UK’s leading infrastructure contractors.
We are committed to working within our own business and our supply chain to ensure business practices are ethical, and to tackle hidden labour exploitation.
Modern slavery is a criminal activity and a violation of human rights. We all have a responsibility to prevent modern slavery and human trafficking happening within our business and supply chains.
Policies
Our accredited business management system makes sure that we operate fair and transparent systems, compliant with all areas of UK legislation. They include policies on:
- Modern slavery
- Recruitment
- Prevention of illegal working
- Fatigue
- Purchasing and supplier approval
- Sub contractor management
- Anti-bribery
- Mental health and wellbeing
- Whistleblowing
- Corporate social responsibility
Identification of risks, prevention and management
We are doing everything we can to combat modern slavery and labour exploitation. We continue to review the risks within our business and our supply chain.
Steps already in place to prevent and manage that risk are:
Recruitment
- Face-to-face individual interviews with all workers to gauge willingness, ability and qualifications to carry out the specific job role
- Stringent verification of identity documents and right to work in the UK documentation carried out by trained staff
- Reference checks on all workers
- An induction providing information on statutory rights and company policies and procedures.
Staff support
- Transparent and detailed terms of engagement provided to all workers
- Detailed payslips provided weekly
- Wages are paid into personal bank accounts
- Fair access to training, development and promotion opportunities
Modern slavery awareness:
- Delivery of modern slavery training sessions and stand-down days for site staff
- Delivery of a bespoke modern slavery presentation to head office staff, focusing on areas of risk, spotting the signs, and how to report it
- Posters displayed in multiple languages in welfare facilities
- Payslip messages
- Social media and staff enews
Due diligence in business and supply chain
VGC was the first labour resourcing company to be awarded the Ethical Labour Sourcing Standard (ELS) BES 6002.
In developing our strategy and policy in relation to modern slavery we have taken the following steps:
- Our group services director has been named one of the Top 100 Modern Slavery influencers. She engages with main contractors and the Gangmasters and Labour Abuse Authority (GLAA) and the Recruitment and Employment Confederation (REC) to work collaboratively with other industry partners to prevent modern slavery.
- We include modern slavery questions in our pre-qualification suppliers questionnaire form.
- Due diligence monthly reports on workers check for:
- duplicate bank account details
- houses with multiple occupancy
- Refresher documentation verification training by the Metropolitan police to all staff involved in recruitment and compliance on how to check the validity of identity documents.
- We carry out periodic internal audits on high risk groups as defined by the GLAA.
- We have key influencers on site who are trained in spotting the signs of modern slavery, and in our reporting process.
Tackling modern slavery plan of action
| Initial modern slavery practices | What we did in 2019 | What we will do in 2020 |
|---|---|---|
| MSA policy in place and published on website demonstrating our commitment to tackling labour exploitation | Methods to monitor and alert risks of labour exploitation | Worker exploitation induction briefing to be included in company HSQE and head office induction |
| Face to face recruitment interview process | Key influencer MS training delivered on spotting the signs of Modern Slavery | Labour exploitation questionnaire in different languages to be sent to all staff |
| Stringent checks on original right to work in the UK documents | Tackle MSA in wider supply chain and procurement and updated supplier approval process to include MS questions | Distribute worker leaflets to staff along with induction booklet in multiple languages |
| UKBA trained staff carrying out validity checking of passports and visas | Investment in new database system which can run MS audit reports detailing if bank account details, mobile numbers, addresses, next of kin details have been duplicated | Worker engagement and communication (multi lingual) |
| Payment for hours worked made into personal bank accounts | HSQE team carries out internal Modern Slavery audits | MS questions to be included in the registration pack for new starters |
| Internal training for staff involved in recruitment on labour exploitation and spotting the signs and whistleblowing | Unseen app added to all company mobile phones | Further training for head office staff and site workers |
| Fair opportunity and access to training, development and promotion opportunities | ||
| Displaying Stronger Together posters across offices and sites |
Reporting
If you have any concerns in relation to modern slavery it is essential that you report them. You can report it to VGC in confidence and anonymously.
- Report to VGC management: Ciara Pryce Ciara.pryce@vgcgroup.co.uk or Laura Perry laura.perry@vgcgroup.co.uk
- Tell your VGC labour manager.
- Use the the whistleblowing form on this website.
You can also report directly to the authorities:
- Modern Slavery Helpline 0808 801 0372 8am to 8pm – 7 days a week
- Download the Unseen.org app
Do not try to deal with the situation yourself unless the person is in immediate danger. If there is immediate danger call the police on 999.