SLAVERY AND HUMAN TRAFFICKING STATEMENT
Grenville is proud of the ethical standards that it has embedded into its business over many years and believes that these standards are consistent with the underlying principles of the Modern Slavery Act 2015. Slavery and the trafficking of people have no place in the modern world, and Grenville considers that the new legislation will become an important part of doing business both in the UK and overseas. We are therefore committed to enhancing our practices to combat slavery and human trafficking.
OUR POLICY ON ANTI–SLAVERY AND HUMAN TRAFFICKING
Grenville Anti-Slavery and Human Trafficking Policy may be found here.
We are committed to ensuring, so far as we are able, that there is no modern slavery or human trafficking in our supply chains or in any part of our business and we take a zero-tolerance approach to slavery and human trafficking. Our supply chains include sub-contractors, suppliers, labour agencies and professional services providers. Our Anti-Slavery and Human Trafficking Policy reflects a long-standing commitment to acting ethically and with integrity in all of our business relationships, supported by the development and implementation of effective systems and controls.
OUR ANTI-SLAVERY AND HUMAN TRAFFICKING ASSURANCE PROCESS
As part of an initiative to identify and mitigate risk in respect of slavery and human trafficking, we have: 2
- Undertaken a slavery and human trafficking risk assessment to enable us to apply a risk-based and proportionate approach to dealing with slavery and human trafficking issues;
- Developed and agreed our Anti-Slavery and Human Trafficking Policy based upon our risk assessment;
- Reviewed the contracts that we have with our supply chain, and amended these to require compliance with the Modern Slavery Act 2015 where appropriate. For those of our supply chain with whom we have entered into a Grenville trading agreement, we have enhanced our audit process to include slavery and human trafficking issues;
- Mandated, where appropriate, that our supply chain be registered with the Constructionline validation system, which requires our supply chain to confirm their compliance with the Modern Slavery Act;
- Widened the scope of Grenville whistle-blowing procedures to include the reporting of modern slavery and human trafficking issues, so that any individual may confidentially raise a potential issue; and
- Begun implementing targeted training for those involved in procurement and/or with responsibility for supply chain management.
Finally, we are currently developing a third party auditing process for targeted, high risk projects in circumstances where we are procuring directly.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business, we will provide training to our staff that is proportionate to the level of risk.
DEVELOPING FOR THE FUTURE
As our approach to slavery and human trafficking develops, we will also devise a process of monitoring and measuring our performance so that we can assess how well we are doing and whether additional procedures may be necessary. We are committed to reporting publicly about our performance each year.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Grenville company for the financial year ending 31 December 2016.