Policies

Modern Slavery and Human Trafficking Statement 2023

Introduction

This statement is made pursuant to S.54 of the Modern Slavery Act 2015 (“the MSA”) and sets out the steps taken by SCAPE Group Limited (“SCAPE”) and its subsidiary companies[1] to prevent modern slavery and human trafficking in its (and their) business and supply chains for the financial year ending 31st March 2023.

SCAPE’s policy is to conduct its business in an honest, open and ethical manner and to act professionally, fairly and with the utmost integrity in all our business dealings. Accordingly, SCAPE aims to ensure that its supply chains and every part of its business are, and remain, free from slavery and human trafficking.

During this reporting period SCAPE continued with its modern slavery programme, which included reviewing its policies and procedures relating to the risk of modern slavery across its own business and operations. It also continued its collaboration with its framework partners. This included monitoring progress on the commitments made for 2022/23, as announced in October 2021.

Central to SCAPE’s commitment to lead the construction sector’s conversation in relation to modern slavery and other forms of labour exploitation was the formation of SCAPE’s Modern Slavery Strategic Partnership, which held its inaugural meeting in July 2022. The aim of the partnership is:

• To provide strategic oversight in support of SCAPE’s commitment to tackle modern slavery and labour exploitation, strengthen the construction sector’s approach to minimising the risk of modern slavery and drive opportunities for change.
• An alliance against exploitation | SCAPE outlined SCAPE’s activity to mark 2022 Anti-Slavery Day.
• In line with the commitments made, the anonymised findings from independent audits conducted across the UK Construction Sector, which included both SCAPE and non-SCAPE projects, were cascaded to framework partners in January 2023. This formed the basis for further commitments which have been agreed by partners in relation to 2023/24.

• In 2023/24, SCAPE will continue with its modern slavery programme in relation to its own business along with leading the SCAPE Modern Slavery Strategic Partnership and engagement with its partners in relation to Ethical Labour.

This statement has been approved by the Board of Directors of SCAPE and signed by Mark Robinson, Group Chief Executive.

[1] SCAPE’s wholly owned trading subsidiaries on behalf of whom this statement is also given include SCAPE Procure Limited (Company No. 09955814), SCAPE Procure Scotland Limited (Company No. SC584373), SCAPE Venture Limited (Company No. 07710482) Lungfish Architects Limited (Company No.09828111) and Construction Waste Portal Limited (Company No. 13768718).

Structure, business and supply chains

SCAPE was established in 2005 as a Private Limited Company under S95 of the Local Government Act 2003 as SCAPE System Build Limited and changed its name to SCAPE Group Limited in April 2016.

SCAPE is jointly owned by its six member authorities: Derby City Council, Derbyshire County Council, Nottingham City Council, Nottinghamshire County Council, Warwickshire County Council and Gateshead Borough Council.

SCAPE offers a suite of performance- managed construction services frameworks, property services, innovative design solutions, community investment opportunities and joint ventures that are available to any public body in the United Kingdom. As a public-sector organisation, SCAPE fully appreciate the role that the built environment plays in the context of service delivery and the local economy.

The single-supplier frameworks offer public sector customers access to a range of construction and construction-related services, property services and design solutions delivered by contractors who have been selected through an OJEU-compliant competitive tender process. These services are made available via access to the frameworks below:

• National Construction Frameworks
• Civil Infrastructure & Engineering Frameworks
• Regional Construction Frameworks
• Professional Consultancy Services Frameworks

Policies relevant to slavery and human trafficking

SCAPE operates a number of internal policies with a view to ensuring that it is conducting business in an ethical and transparent manner.

In 2022/23 SCAPE undertook a review of its policies and procedures in relation to how modern slavery and labour exploitation is addressed. Nine policy and guidance documents were reviewed. The suggested amendments are under consideration within the internal review process.

Relevant policies include:

• Corporate Social Responsibility Statement: Through this statement, SCAPE acknowledges that its operations will impact upon the economy, society and its employees and is committed to ensuring those effects maximise the positive impacts and minimise the negatives so that the business is run responsibly and in a sustainable manner.
• Code of Conduct: The Code of Conduct makes clear the expectation placed on SCAPE employees to maintain the highest standards of conduct and behaviour when representing the organisation; the Code also covering policies relating to the avoidance of conflicts of interest, impartiality, hospitality, political neutrality and whistleblowing.
• Statement of Ethics: This clearly demonstrates SCAPE’s pride in its reputation for acting fairly and ethically in doing business and the values, commitment and integrity of its employees; the statement also covers the policy relating to anti-bribery and corruption.
• Anti-Slavery and Human Trafficking Policy: This policy specifically prohibits activities linked to slavery, servitude, forced labour and human trafficking and sets out exactly what is expected of SCAPE’s staff and supply chain in order to prevent it.

Due diligence and steps to assess and manage the risk of slavery and human trafficking in our business and supply chains

In respect of its own operations, SCAPE considered the location of its activities, the roles being performed, the recruitment processes and the absence to date of reports of concerns regarding slavery and human trafficking. SCAPE undertakes “right to work” checks on all its employees prior to them commencing their role. This includes checking, where applicable, that the employee has a valid work visa and is of an appropriate age to work.

Based on these risk assessments, SCAPE deems the risk of human trafficking within its own staff (including agency and contract staff under direct supervision) to be minimal.

SCAPE recognised that the risks within its own supply chain for goods and services needed to be assessed and a modern slavery risk assessment was undertaken in 2022/23. The findings within this assessment will form the basis for a review of the Group Procurement Policy, which will supplement the policy review already conducted. This will include a review of the due diligence process.

As for contractor supply chains, SCAPE conducts due diligence on all contractors and suppliers as part of the tendering exercises. This has not identified any issues of concern during the reporting period.

Furthermore, SCAPE’s framework procurements are governed by the Public Contracts Regulations 2015 and SCAPE uses the standard supplier questionnaire, PAS 91, to ensure responsible and compliant procurement. Although the MSA is not covered in PAS 91, SCAPE asks a supplemental question to establish the steps a bidder has taken to ensure that slavery and human trafficking is not taking place in any part of its business or in any supply chain member.

SCAPE’s assessment of a bidder’s response considers the information they provide in respect of compliance and the procedures they have in place to meet the requirements under the MSA.

In each of the signed frameworks, contractual clauses are included to address slavery and human trafficking in the supply chain and cover:

• Compliance with the MSA
• Sub-contracting
• Immediate notification of any actual or suspected breaches of the organisation's policies and any actual or suspected slavery or human trafficking of which it becomes aware or has reason to believe has occurred or might occur.
• A warning that failure to comply with these requirements will be deemed to be a substantial failure to comply with the requirements of the framework agreement (substantial failure being capable of occasioning termination).

As a managed framework provider, SCAPE carries out annual audits on all framework contractors. Compliance with the MSA forms part of this annual audit. Evidence is collected for each audit requirement and this is assessed in terms of compliance with legal requirements and/or performance measures. If SCAPE has reason to believe that a contractor or supplier may have been in breach of its requirements and expectations with regard to the use of slave or bonded labour, SCAPE will report this to the Gangmasters and Labour Abuse Authority (GLAA) who will take any appropriate action or offer further guidance.

Performance indicators

To date SCAPE has adopted a continuous improvement approach to its performance in this area, this will continue.

As stated above, SCAPE undertakes a programme of audits on all framework contractors. During 2022/23 39 audits were conducted.

The modern slavery risk assessment conducted during 2022/23 identified that there are a number of service providers which fall into high and medium risk categories for labour exploitation. SCAPE will consider steps to reduce the number of high and medium risk suppliers where it is practical to do so.

The programme of audits undertaken by framework partners to meet the 2022/23 commitments resulted in 65 audits being conducted. The primary focus was on site audits and worker interviews, with a limited number of management system audits.

In order to address the findings, and give a greater understanding of the sector’s approach to labour exploitation, auditing in 2023/24 will focus on management system audits. Although this may reduce the number of audits conducted it should increase the number of workers (either employed, contracted or sub-contracted) which are covered.

The information obtained in 2023/24, when combined with that of 2022/23, will help determine the steps to be taken in 2024/25.

Training

The SCAPE modern slavery and ethical trading module was completed by 95% of SCAPE’s employees in 2022/23.

In addition to this, SCAPE is in dialogue with the Supply Chain Sustainability School in order to develop a learning pathway to provide additional training for key roles, these will include Procurement, Contract Managers and Framework Managers.

Additionally, this will support the School through the development of modules in these areas for use by the sector more widely. Providing a route for training and awareness which can be utilised by framework partners if required.

Responsibility for compliance

The Managing Director of each subsidiary or associated company is responsible for their company’s compliance with the SCAPE Anti-Slavery and Human Trafficking Policy and the MSA. The Managing Directors are advised and supported by SCAPE’s Heads of Human Resources, Procurement and Legal & Governance.

Objectives for 2023/24

The objectives for 2023/24 are set out below. These incorporate activities across SCAPE and its operations.

SCAPE will:

• Develop and implement a Group Procurement Policy for suppliers of goods and services.
• Reduce the number of “high and medium risk” suppliers used by SCAPE Group Ltd where practical to do so.
• Develop and promote a Learning Pathway for key roles in conjunction with the Supply Chain Sustainability School.
• Undertake an internal programme of awareness raising.
• Develop and implement a communication plan in relation to labour exploitation.
• Support National and Regional Framework Partners through the work of the Modern Slavery and Ethical Working Group.
• Provide feedback to Framework Partners in relation to the findings of independent audits conducted, to include any emerging threats and trends.
• Lead a strategic partnership comprising recognised UK leaders on the modern slavery agenda and seek opportunities for further cross industry collaboration.

Approval

This statement was approved by the Board of Directors of SCAPE Group Limited on 4 August 2023.

Mark Robinson

Group Chief Executive

SCAPE Group Limited