Leeds D&B One Limited (“the Company”)
Modern Slavery Statement & Human Trafficking Statement
for the financial year to 30th September 2018
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the Company has taken and is continuing to take all reasonable endeavours to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Company has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
The Company was formed as a special purpose vehicle to undertake contracts to design and build schools for our client, Leeds City Council.
The Company operates a number of policies to ensure that it is conducting business in an ethical and transparent manner, including anti-bribery, Health & Safety, and Data Protection. The policies explain the manner in which we behave as an organisation and how we expect our suppliers to act.
The Company has no direct employees; however, it does have in place a Management Services Agreement with Albany SPC Services Limited (“Albany”), which provides the services of a Finance Officer, Company Secretary, General Manager and other management staff to the Company. Albany operates a robust recruitment policy, including eligibility to work in the UK, and checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
The Company works with key supply chain partners. To date, construction work has primarily been subcontracted to Interserve Construction Limited (“ICL”). However, ICL does not have sole rights to the subcontracted work and during the year, three other subcontractors, namely Geo Houlton & Sons (Holdings) Limited (“Houlton”), Henry Boot Construction Limited (“Henry Boot”), and Portakabin Limited (“Portakabin”) have been used to deliver building works.
Prior to the subcontracts being signed, due diligence was undertaken into the financial status, operating policies and practices, including ethical and Health & Safety, of the subcontractors who were required to hold any required accreditations or appropriate qualifications for the services that they would deliver; their appointments were approved by the Company’s Board and our client.
The Company recognises that there is a risk of slavery and human trafficking in the construction and facilities management sectors, and therefore, expects ICL, Houlton, Henry Boot, and Portakabin to adhere to a policy of zero tolerance to slavery and human trafficking both within their own organisations and in any of their own supply chain partners who may provide services on their behalf to the Company, and has sought and received assurances and evidence of their policies and operational practices in this respect.
The Company intends to provide this statement to its key supply chain partners and to monitor their policies.
This statement will be reviewed on an annual basis.
This statement was approved by the Board of Directors on 25 March 2019.
This statement was signed on behalf of Leeds D&B One Limited on 25 March 2019 by Peter Johnstone, Director.