Modern Slavery and Human Trafficking Statement

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.

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 takes a zero-tolerance approach to modern slavery and human trafficking and aims to ensure that its supply chains and every part of its business are, and remain, free from slavery and human trafficking.

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) and Lungfish Architects Limited (Company No.09828111). 

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 fully 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, we fully appreciate the role that the built environment plays in the context of service delivery and the local economy.

All our services have been designed to support the entire lifecycle of the built environment, to help create a smooth procurement journey, to stimulate local growth in communities and to deliver demonstrable outcomes on every project. Sustainability and social value are embedded in our business culture.

Our 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 listed here.

Policies relevant to slavery and human trafficking

Scape operates a number of internal policies with a view to ensuring that we are conducting business in an ethical and transparent manner:

  • 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
  • Equalities Action Plan: The Plan expounds our commitment to treating people fairly, prioritising work-life balance and an inclusive recruitment and selection policy
  • Code of Conduct: The Code of Conduct makes clear the expectation we place on our employees to maintain the highest standards of conduct and behaviour when representing the organisation. The Code also covers policies relating to the avoidance of conflicts of interest, impartiality, hospitality, political neutrality and whistle-blowing 
  • Statement of Ethics: This clearly demonstrates our pride in our reputation for acting fairly and ethically in doing business and the values, commitment and integrity of our employees. The statement also covers our 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 our staff and supply chain in order to prevent it
  • Whistle-blowing Policy: We encourage all employees to report any concerns related to our activities or those of our contractors and supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking

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

We have undertaken risk assessments of slavery and human trafficking within our own operations as well as those of our contractors and supply chains and seek to continue to develop systems and processes to mitigate any risks we perceive.

Since our services and the resulting construction activities take place largely in the UK, we consider the risk very low and we currently have no activities (nor are we aware of any activities on the part of our contractor supply chains) in areas deemed to be of high or medium risk.

In respect of our own operations, we considered the location of our activities, the roles being performed, the recruitment processes and the absence to date of reports of concerns regarding slavery and human trafficking. We also undertake “right to work” checks on all our 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, we deem the risk of human trafficking within our own staff (including agency and contract staff under our direct supervision) to be minimal. As for our contractor supply chains, again these are almost exclusively UK-based operations, which lessens this risk. We conduct due diligence on all our contractors and suppliers as part of our tendering exercises.

Furthermore, Scape’s framework procurement is 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, we do ask 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. Our 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 our signed frameworks, robust and effective 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, we regularly carry out annual audits on all our 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. Any weaknesses or other concerns which are identified will be discussed with the contractor and, if necessary, remedial action will be taken.

We have also resolved to sign up to the Gangmasters & Labour Abuse Authority (“GLAA”) Construction Forum protocol to support the GLAA’s work against modern slavery in construction chains. Going forward, we plan to provide a training programme for current and new staff (as part of our induction programme) on a range of topics, including issues relating to modern slavery and human trafficking and compliance matters.

Our performance indicators

We intend to adopt a continuous improvement approach to our performance in this area. We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
• Any reports or concerns regarding slavery or human trafficking in our operations or supply chains are identified
• Staff training on the MSA has not been completed, primarily by those in key roles to identify and address potential modern slavery risks including Human Resources, Legal and Procurement functions, by the target date

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 & Audit and Legal & Governance. 

Approval
This statement was approved by the Board of Directors of Scape Group Limited on 2 November 2018.

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