Modern Slavery and Human Trafficking Policy
The Woodhead Group is owned and operated by a new generation of the Woodhead family, focusing on three key business areas:
- Woodhead Construction (Robert Woodhead Ltd) – comprising a number of distinct specialisms enabling the group to offer customers dedicated teams in affordable housing (Woodhead Living) conservation and consultancy services (Woodhead Heritage) refurbishments, repairs and maintenance (Woodhead Improve) and projects for schools, colleges and universities (Woodhead Education).
- Woodhead Enterprise Ltd – which manages the Woodhead commercial properties in Nottinghamshire and Lincolnshire.
- Woodhead Regeneration Ltd – focuses on three key areas: land and works opportunities with public sector partners; joint ventures and Woodhead Homes, which brings to market beautifully designed new homes
We have a number of policies that are designed to manage the risks relating to modern slavery and human trafficking issues, including the Company’s Anti-slavery and Human Trafficking, Anti-bribery, Equal Opportunities & Dignity at Work, Disclosures in the Public Interest, Conduct Whilst on Company Business policies and the Disciplinary and Grievance policy rules all define the Company’s required high standards of ethical behaviour that ensure there is no slavery or human trafficking in any parts of its business.
These set out our position of zero tolerance of modern slavery and human trafficking in any form in our business and supply chain. We are committed to acting ethically and with integrity in our business dealings and relationships and to maintaining systems and controls designed to ensure modern slavery and human trafficking are not taking place in our business or across our supply chain. Our Whistleblowing Policy provides a mechanism for our employees and others working in our supply chain to report suspected breaches of these policies.
We are aware that risks arising from modern slavery and human trafficking can apply anywhere in our operations, whether through direct employment, sub-contracted employees or the supply of materials. We expect our suppliers and subcontractors to ensure that there is no slavery or human trafficking in their supply chain. Where issues are identified (including through our audit process) that are not resolved to our satisfaction, we review the on-going nature of the relationship with that relevant organisation.
Our approach to assessing and managing risk
1. We have a Group-wide policy confirming our zero tolerance of modern slavery and human trafficking.
2. Our processes require that our sub-contractors and suppliers acknowledge their responsibility for adhering to our policies.
3. We have undertaken risk assessments to identify the key risks in our supply chain and review those risk assessments regularly.
4. Our contractual terms include obligations on our sub-contractors and suppliers to comply with our policies, including our Anti-slavery and Human Trafficking Policy.
5. We undertake checks on new recruits to ensure that they are eligible to work in the relevant country of employment.
6. We continue to monitor the effectiveness of our actions against the risk of modern slavery and human trafficking. This includes reviewing our policies and our procurement standards and implementing an audit programme.
We will continue to monitor the effectiveness of our actions against modern slavery and human trafficking.
Next steps will include:
1. Delivering training to key employees on the risks of modern slavery and human trafficking and our processes to mitigate these. Continuing to train employees on identifying any potential issues within our operations and supply chain.
2. Continuing to develop further standards to support our Anti-slavery and Human Trafficking Policy (and related policies).
3. Keeping our pre-qualification standards for the appointment of new suppliers and subcontractors under review.
4. Updating the assessment of risks of modern slavery in our business and our supply chain.
5. We undertake audits of certain key supply chain partners to understand and validate the controls in their organisations and provide an opportunity to learn from best practice.
6. We issue minimum procurement standards for certain, high risk categories of materials and products.
7. We look to sign up to the Gangmasters & Labour Abuse Authority (GLAA) construction protocol.
This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015 and constitutes Woodhead Group’s modern slavery and human trafficking statement for the financial year ending 31 October 2018. It was approved by Woodhead Group’s board of directors on 11th April 2019.
Signed on behalf of the board of directors by:
Teresa Westwood – Managing Director
11 April 2019