SLAVERY AND HUMAN TRAFFICKING STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes our slavery and human trafficking statement for the financial year ending 30 June 2018.
A review of our Slavery and Human Trafficking Statement was undertaken during the course of the year. We remain committed to trading ethically with zero tolerance for modern slavery human rights violations and child labour and improving our practices to combat slavery and human trafficking.
Formation Group plc is a large housebuilder and is listed on the London Stock Exchange and we are a FTSE 250 listed company. We are the parent company of the Group’s trading company ? providing housebuilding and related services. The Group has nearly ? employees and operates in the United Kingdom.
Our business is organised for operational purposes into Divisions across the United Kingdom.
OUR SUPPLY CHAINS
We procure a wide range of goods and services through a diverse supply chain, which includes:
- Main Contractors;
- Subcontractors who provide materials, labour and plant;
- Manufacturers & Suppliers who deliver direct to site or to the Subcontractor;
- Utility Companies; and
- Professional & Specialist Consultants linked to core activity.
A number of our suppliers will have turnovers in their own right which trigger a requirement to comply with the obligation to produce a Slavery and Human Trafficking Statement under the Act. In any event we actively encourage all of our suppliers notwithstanding the contents of the Act to ensure that they comply with the spirit and intent of the Act.
We have a stable supply chain allowing us to benefit from a significant number of long standing trading relationships with likeminded Subcontractors, Suppliers and Consultants who share our values and ethics.
The materials that are ordered directly by our Regions or indirectly by our subcontractors are procured, in the main, under a National Supply Agreement by our Group Commercial Department who apply rigorous due diligence and tender processes.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policy reflects our 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 in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
Following the publication of the Act, we have strengthened our approach to ethical and responsible sourcing through a number of key initiatives.
All Suppliers and Manufacturers must submit a detailed Supplier Appraisal Assessment for approval as part of our pre-tender qualification process. We have updated the appraisal forms to track the Country of manufacture allowing us to identify materials supplied by manufacturers with a high risk profile.
Our supply partners have to warrant that they shall comply and will use their best endeavours to ensure that any subcontractor or party within their own supply chain shall at all times comply with the Act.
We have updated our Standard Purchase Order and Subcontractor Terms of Contract requiring trading partners to comply fully with the Act, with any breach resulting in the termination of all live contracts.
The steps we have taken will help to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values a Code of Conduct is being developed that will be sent out annually requiring all suppliers and subcontractors to confirm their commitment
We have a dedicated compliance team, which consists of representatives from the following departments: Legal, Audit and Compliance, Human Resources, Procurement and Sales.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff and suppliers/providers.
We will carry out a review exercise at least once a year to gauge the effectiveness of this policy and will look to ensure that we are adopting best practice through the assessment of merging case law.
Formation Group plc
Date: 3 April 2019