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 and relates to actions and activities during the financial year 1 March 2019 to 29 Feb 2020.

As part of the construction industry, we recognise our responsibility to take a robust approach to slavery and human trafficking. We are wholly committed to preventing slavery and human trafficking in all our business activities and to ensuring that our supply chain is free from slavery and human trafficking.

 

About Highwood Group

Established in 1987 we have delivered an extensive portfolio of projects across the south coast of England that includes house building, care home construction and land acquisition and planning. Situated in Romsey, Hampshire, our Head Office is home to our central and support teams and each site we manage houses our onsite project team specific to that build.

The Highwood Group complies with all relevant employment law legislation and we expect our suppliers and sub-contractors to do the same.

 

Policy

Our policy reflects a 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 within our business or that of our partners or supply chains.

 

Procedures

Our key risk is in our supply chain and are conscious that the industry we work in can include areas of high risk, with roles that can provide opportunities for exploitation. We are committed to ensuring that there is no slavery or human trafficking in our supply chains, and it is our policy to implement effective and robust controls to ensure this is not taking place.

All new suppliers undertake a level of due diligence before they are accepted as a supplier, including a comprehensive supplier questionnaire which includes confirmatory statements around a commitment to ensuring compliance with the modern slavery act.

We are also updating our terms and conditions with current suppliers such that we are requesting a commitment for them to adhere to the modern slavery act and that they, in course, also hold their suppliers to account over modern slavery.

 

Supply Chain

Our supply chain involves local and national companies. Materials and goods that make up our builds may include raw materials from, or may be assembled in, countries that at are at a high risk of slavery and/or human trafficking. Our procurement team are responsible for the management of this area and work closely with suppliers to make sure they are aware of the potential for slavery and human trafficking.

The processes stated also include provisions to ensure that the expectations and obligations are passed down the supply chain and not restricted to the immediate link in the chain that is most visible. We will report any evidence or suspicion of cases or hidden third party labour exploitation to the Gang masters and Labour Abuse Authority immediately. Failure by managers and leaders of the company, third party labour providers or organisations in the labour supply chain to act upon concerns of worker maltreatment, coercion or harassment will be regarded as potential gross misconduct and will be managed accordingly through the relevant disciplinary process.

 

Whistle-blowing

We encourage all our workers, customers and business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistle-blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Information is available on notice boards on all sites for suppliers and sub-contractors and through our HR portal for all employees. Our full whistle-blowing policy is available in our Employee Handbook and upon request. Workers are also able to report concerns via Public Concern at Work’s confidential helpline, 020 7404 6609.

 

Training

All new site staff attend an induction session which, from 2019, included a section on Modern Slavery. For all workers with access to our HR portal, all documents relating to Modern Slavery and Human Trafficking our available to view and download. We are able to monitor this and provide additional training when required.

 

Further Steps

During 2019 we intend on introducing induction training to all new staff relating to modern slavery awareness. We are also strengthening our supplier terms and conditions to reference adherence to the modern slavery act.