Modern Slavery and Human Trafficking Policy

Modern Slavery, Illegal Workers and Human Trafficking Statement

County Contractors are Principal Contractors delivering specialist fit-out renovations, refurbishment, and re-modelling for the Hotel and Retail sectors countrywide. We also provide a bespoke service for both planned and reactive maintenance, and electrical contracts. Our supply chains therefore can be multinational and involve many businesses and people, some of which are engaged directly and some on a subcontract basis.

We are committed to maintaining the highest standards of ethical conduct and social responsibility, so we strongly condemn modern slavery, human trafficking, and the employment of illegal workers. We all have a duty to be alert to risks, however small and our workers are expected to report their concerns and the management to act upon them. This policy outlines our approach to preventing these practices and ensures compliance with relevant legislation, including Sections 15 to 25 of the Immigration, and the Asylum & Nationality Act 2006. The company will achieve this by ensuring the following:

• Worker training in order establish understanding of requirements.
• We have a zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.
• Stringent vetting and investigation of our supply chain (employees, Labour-Only Subcontractors Subcontractors, Suppliers, policies, and contracts).
• Continually audit & review our practices for checking all workers are paid at least the minimum wage and have the right to work.
• We encourage the reporting of concerns and the protection of whistle blowers.
• The company will not knowingly support or deal with any business involved in slavery or human trafficking.

[fs-toc-H2]Modern Slavery and Human Trafficking

Modern slavery encompasses various forms of exploitation, including slavery, servitude, forced or compulsory labour, and human trafficking.

Human Trafficking is the recruitment, transportation, transfer, harbouring or receipt of people through force, fraud or deception, with the aim of exploiting them for profit.

Awareness:

A large number of victims of slavery are within the UK construction industry and some victims may be subject to violence and under the control of gang-masters. The traffickers often use violence or fraudulent employment agencies and fake promises of education and job opportunities to trick and coerce their victims. Victims are forced to work in factories, on construction sites or in the agricultural sector without pay or with an inadequate salary, living in fear of violence and often in inhumane conditions.

We therefore ensure that we raise awareness among our workers about the importance of preventing Modern Slavery and Human Trafficking by outlining the warning signs that something is wrong, and how to report suspicions or concerns. This may include training Toolbox Talks to identify signs of exploitation, communication campaigns, posters, and regular updates on this policy.

[fs-toc-H2]Illegal Workers

Illegal workers refer to individuals who do not have the legal right to work in the country where they are employed.

Awareness:

Illegal workers are migrant workers who are working in a host-country without the proper entitlement and authorization to do so. They are subject to immigration control and either do not have leave to enter or remain in the UK, or who are in breach of a condition preventing them from taking up the work in question. Employers can be fined or possibly imprisoned for knowingly employing illegal workers, or not making the proper checks.

Eligibility to Work Verification:

We are committed to maintaining the correct processes to ensure all prospective workers are legally permitted to work in the UK. We undertake inspections and audits to ensure our standards are being implemented and that the local legislation and regulations are complied with:

• Our own Right to Work checks in line with the Home Office Guidance - Comprehensive Guidance for Employers on preventing Illegal Working, are to be carried out for all employees and labour-only subcontractors.
• Confirmation that checks are made on any bonafide subcontractors, or employment agencies we will be contracting with.
• All documents provided as proof of right to work will be verified by a Manager in person, with a signed and dated copy held on and records retained for at least 2 years after the individual has left our employ.
• Failure to provide valid proof of the right to work in the UK will result in a retraction of the offer of work.

Review of Verification:

Controls are in place so that the periodic follow-up checks will be made to confirm right to work as follows:

• For individuals with time-limited permission to work in the UK, the Company will request that evidence of their renewed right to work in the UK is provided prior to the expiry date of their current document. Proof of a valid application for a renewed right to work document will also be accepted in instances where this is yet to be granted.
• Our Approved Subcontractor Database has annual checks of all our Bonafide subcontractors, including a right to work confirmation.
• We work directly with recruiting agencies and ensure periodic checks and controls of their right to work.

Nationality Verification:

To ensure compliance with legal requirements, we will implement appropriate procedures to identify the nationality of foreign workers. This may involve collecting data such as passport information, visa details, or immigration status. The collection and storage of this data will be in accordance with applicable data protection laws

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[fs-toc-H2]Training and Awareness

We expect all our workers to share our commitment to preventing modern slavery, human trafficking, and the employment of illegal workers. We will assess their compliance with this policy and take necessary actions to address any concerns as follows:

• We will raise awareness among our workers about the importance of preventing modern slavery, human trafficking, and the employment of illegal workers. This may include training Toolbox Talks, communication campaigns, posters, and regular updates on this policy. The TBT will focus on identifying signs of exploitation, understanding legal obligations, and reporting any suspicions or concerns.
• All employees involved in the recruitment and employment processes will receive appropriate training to understand the risks associated with modern slavery, human trafficking, and the employment of illegal workers.

[fs-toc-H2]Suspicions and Reporting a Concern

We will ensure that all workers are aware of the steps to take by signposting how to raise a concern through National Helplines via site training and posters.

[fs-toc-H2]Monitoring and Review

We will carry out an annual risk assessment to identify the areas in the business that require the most attention. We will undertake an ongoing review process to ensure our workers can identify and report any instances of suspected non-compliance.

We will assess any instances of non-compliance on a case-by-case basis and tailor remedial action appropriately. We will only trade with those who fully comply with this statement and our policies or those who are taking verifiable steps towards compliance.

This policy will be regularly monitored to ensure that the aims are achieved.