Modern Slavery Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes CONWAY AECOM’s slavery and human trafficking statement for the financial year ended 31 March 2019.
CONWAY AECOM is a joint venture between F M Conway Limited (“FMC”) and AECOM Limited. CONWAY AECOM (“the Company”) reported a turnover of £41.7 million for the year ending 31st March 2019. It is an integrated multidiscipline highways infrastructure service provider, delivering vital services in transportation, the built environment and open spaces for communities and business. It carrys out services through its self-delivery model, by combining design and consultancy expertise with front line operational excellence. It inspects, designs, builds, produces, enhances and maintains essential infrastructure services for the community.
The Company is committed to achieving the highest level of ethical standards and has governance arrangements in place to ensure integrity and objectivity throughout its business activities. The company embraces the principles of fairness, inclusion and respect in everything it does, and is proud of the steps it has taken to combat slavery and human trafficking.
Our Supply Chain
During the year the Company used 152 suppliers and subcontractors to support its business, all of which are UK based. It had no direct spend with suppliers determined as high risk by the Global Slavery Index
The Company is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. The Company’s Code of Conduct reflects its position of zero tolerance of modern slavery and human trafficking in any form and reinforces its commitment by acting ethically and with integrity in all its business relationships.
Its Ethical and Sustainable Procurement Code sets out standards with respect to buying goods and services, which forms part of its contractual relationship with suppliers.
The Company is committed to achieving the highest level of ethical standards and strives to ensure integrity and objectivity in all its business dealings. It is the Company’s responsibility to provide employees and members of its supply chain with a safe and confidential mechanism to raise concerns and report breaches of its standards, processes and protocols. Its Whistleblowing Policy provides a mechanism for its employees to report any concerns or suspected breaches of policy.
During the year the Company launched its Speak Out helpline and mobile App that enables employees and others to raise concerns or to seek advice on any matters related to compliance with the law / ethics and the Company’s Code of Conduct. The Speak Out helpline is accessible to its employees and third parties with whom the Company has a relationship (including contractors, customers, suppliers and the general public) to report on any suspected concerns.
Due Diligence Process
The Company carries out detailed due diligence checks on its supply chain, which include reviewing risks of modern slavery and human trafficking. The Company has systems to identify and assess any area of potential risk of transgression of its business ethics and to protect whistle blowers.
The Company is aware that risks can arise from modern slavery and human trafficking from all aspects of its business, notably through recruitment practices (including subcontracted employees), operational site management and supply of materials. It carries out risk assessments on its supplier and subcontractor chain to ensure that they are compliant with the Modern Slavery Act. Where issues are identified (including through its audit processes) that are not resolved to its satisfaction, it would review the on-going nature of the relationship. The Company would remove any non-compliant organisations from its approved supplier list where issues identified remain unresolved.
Our Effectiveness in Combating Slavery and Human Trafficking
Pursuant to the shared services arrangements between CONWAY AECOM and FMC, the Company has access to FMC’s wide-range of training materials on modern slavery and human trafficking. FMC is a signatory to the Gangmasters & Labour Abuse Authority Construction Protocol and as such, the Company is kept abreast of any associated risks to modern slavery within the construction industry and how to combat such risks.
Further, as part of its ongoing commitment to combating modern slavery and human trafficking, the internal audit department will review procurement processes across the organisation to highlight any potential risks.
To ensure greater understanding of the risks of modern slavery and human trafficking presents to the Company’s supply chain and business, training in modern slavery is provided to those responsible for procurement. More general business ethics training (encompassing modern slavery) is given to all employees.
The Company’s business ethics are publicised internally and are available to its subcontractors and other members of the supply chain.
As part of the Company’s continued commitment to improving compliance with the Modern Slavery Act 2015, it is embarking on the following initiatives:
An on-going review of policies to ensure the workforce understand that the business is committed to acting ethically with integrity and has a zero tolerance to modern slavery or human trafficking.
Our Supply Chain:
To review the pre-qualification questionnaire and suppliers’ terms & conditions to re-enforce its commitment to anti-slavery and human trafficking and to ensure this message is embedded within the supply chain;
To review subcontract labour terms & conditions to reflect the Company’s position of zero tolerance with any form of modern slavery or human trafficking.
To maintain a Company-wide campaign that actively promotes the ‘signs to spot’, focus on how employees can identify if modern slavery is present in the supply chain. The initiative will encompass the whole workforce and is publicised to all employees.
Promote at weekly induction events the ‘signs to spot’ that may indicate a worker is at risk of being exploited.
To continue to update training material in a variety of languages to ensure training is accessible to the whole workforce.
This statement has been approved by the Board of CONWAY AECOM LIMITED and is signed on its behalf.