Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy sets out R&B M&E Ltd actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

R&B M&E Ltd recognises that it has a responsibility to take a robust approach to slavery and human trafficking; however, the Modern Slavery Act 2015 only requires organisations with a turnover of more than £36m to publish an annual statement.

R&B M&E Ltd is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of R&B M&E Ltd

Building Services Engineers

The organisation currently operates in the following countries:

United Kingdom

The following is the process by which the company assesses whether activities are high risk in relation to slavery or human trafficking:

• Only bone-fide Distributor Companies of branded materials/goods are used as approved​ suppliers.
• Only bone-fide UK based sub-contractors are used where required to fulfil certain contracts.
• R&B M&E Ltd do not carry out work outside of the United Kingdom, and therefore do not feel that any of their activities to be of a high risk of slavery or human trafficking.

The Managing Director takes overall responsibility for the organisation’s anti-slavery initiatives within the relevant areas below:

• Policies
• Risk assessments
• Investigations/due diligence
• Training

Relevant policies

R&B M&E Ltd operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy R&B M&E Ltd encourages all its workers, customers and other 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. The organisation’s whistle-blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation (see Employee Handbook for details).

Employee Code of Conduct R&B M&E Ltd makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.

Supplier/Procurement Code of Conduct R&B M&E Ltd is committed to ensuring that its suppliers adhere to the highest standards of ethics. Goods and services are generally procured from UK based distributors of National or Global organisations. No purchases are made through the internet outside of the UK, using online outlets e.g., eBay, etc.

Recruitment/Agency Workers Policy R&B M&E Ltd uses only specified, reputable employment agencies to source labour.

Recruitment of Direct Staff R&B M&E Ltd requires proof of identity, and eligibility to work within the UK prior to taking on new employees. Copies of Passport and National Insurance number are taken prior to employment.

Due Diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.

• Mapping the supply chain broadly to assess products or geographical risks of modern slavery and human trafficking.
• Evaluating the modern slavery and human trafficking risks of each new supplier.
• Reviewing on a regular basis all aspects of the supply chain by conducting supplier assessments.

Training

The organisation requires staff working within supply chain management/HR department to complete awareness-raising training on modern slavery. This training would take in the following such issues:

• The basic principles of the Modern Slavery Act 2015
• How employers can identify and prevent slavery and human trafficking
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• What external help is available, for example through the Modern Slavery Helpline.

Our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage.

• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
• How to identify the signs of slavery and human trafficking
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.​

Management approval

This policy has been approved by the Managing Director, who will review and update it annually.

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