Company Policy Statement
This statement is made by Highwood Group Limited and has been approved by the Board in accordance with section 54 of the Modern Slavery Act 2015. It relates to actions and activities during the financial year beginning 1st July 2023 (to December 2024).
As part of the construction industry, we recognise our responsibility to take a robust and proactive approach to modern slavery and human trafficking. Highwood Group is wholly committed to preventing any form of slavery or human trafficking in all our business activities and ensuring that our supply chain is free from such practices.
About Highwood Group
Established in 2004, we have delivered an extensive portfolio of projects across the south coast of England, including house building, care home construction, land acquisition, and planning. Situated in Romsey, Hampshire, our Head office team supports all our construction sites, each managed by an on-site project team dedicated to each build.
We comply with all relevant employment law and expect our suppliers and subcontractors to adhere to the same standards.
Policy
Our policy reflects our unwavering commitment to acting ethically and with integrity in all business relationships. We have implemented and continuously enforce effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our business or supply chains. This includes updated measures in line with evolving best practices to combat these issues.
Procedures
We recognise that our key risk lies in our supply chain, particularly given the construction industry’s exposure to roles that may provide opportunities for exploitation. We remain vigilant and committed to preventing modern slavery in our supply chain, ensuring robust processes and controls to detect and eliminate any potential exploitation.
All new suppliers undertake a level of due diligence before appointed, including a thorough supplier questionnaire with statements confirming their commitment to the Modern Slavery Act. We regularly review and update our terms and conditions with current suppliers, ensuring they also commit to the Modern Slavery Act and hold their own suppliers accountable.
Supply Chain
Our supply chain involves both local and national companies. We acknowledge that some materials may originate from or be assembled in countries considered high-risk for slavery and human trafficking. Our procurement team actively monitors this area and works closely with suppliers to ensure they understand the risks and uphold our standards.
We require that these obligations extend throughout the entire supply chain, not just immediate partners. Any evidence or suspicion of third-party labour exploitation will be reported to the Gangmasters and Labour Abuse Authority (GLAA). Failure by company managers, third-party labour providers, or organisations in our labour supply chain to address worker maltreatment, coercion, or harassment will be treated as potential gross misconduct and addressed through appropriate disciplinary procedures.
Whistle-blowing
We encourage all employees, customers, and business partners to report any concerns related to the direct activities or supply chains of the company. This includes concerns about any risks of slavery or human trafficking. Our whistleblowing procedure provides a safe, confidential way for workers to make disclosures without fear of retaliation.
Information is readily available on site notice boards for suppliers and subcontractors and via our HR portal for all employees. Our full whistleblowing policy is detailed in our Employee Handbook and is available upon request. Workers can also report concerns through Protect’s confidential helpline at 020 3117 2520.
Training
All new site staff attend an induction that includes a section on Modern Slavery and Human Trafficking. Key documents related to this issue are accessible through our HR portal for all employees. We have introduced annual online training for all staff, which is mandatory for both new and existing employees to ensure continued awareness and vigilance on the issue of modern slavery.
Further Steps
We are continuously reviewing and enhancing our approach to modern slavery prevention. We will continue to ensure online training for all staff, reviewed annually.
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Authorised for issue by:
Natalie Brown
Group Finance Director, Highwood Group Holdings Ltd
31st December 2024