INTRODUCTION

This Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) relating to Transparency in Supply Chains. Spokemead plc (“Spokemead”) (“Company”) recognises that it has a responsibility to take a robust approach to slavery and human trafficking and indeed takes a zero-tolerance approach to non-compliance with the Act in any part of its business or its supply chain.

We are taking the appropriate steps to ensure that everyone who works for Spokemead benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.

This is the second such statement Spokemead has made and this will continue to be reviewed and updated annually in accordance with the Act.

ORGANISATIONAL STRUCTURE

Having operated as the Main Term Contractor for London’s largest borough for over 25+ years and currently contracted as the term contractor for the Communal Lighting and Electrical Testing Contract (South) we have a proven track record in delivering quality services in a competitive and demanding environment.

OUR BUSINESS

We are structured to provide a first-class service for all our clients for electrical repair, maintenance, installation and testing. Always striving to ensure quality is never compromised, whilst priding ourselves on our reliability.

OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING

We recognise the interdependence of culture and controls and believe that we can achieve more, if our people, business partners and suppliers understand the importance of their roles and take individual and collective responsibility in helping to eliminate the risk of modern slavery.
Spokemead remains committed to ensuring that there is no modern slavery or human trafficking in its supply chain or in any part of its business with a zero tolerance for non-compliance.

This statement reflects that commitment to acting ethically and with integrity in all Spokemead business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chains.
Spokemead operates under a number of policies, which ensure business is conducted to the highest ethical standard including:

  • The Company’s Employee Handbook, which covers a range of ethical and conduct related policies
  • Equality & Diversity Policy
  • Health and Safety Policy
  • Corporate Social Responsibility Policy
  • Environmental Policy
  • Residents and Customers with Special Needs Code of Conduct
  • Equal Opportunities Policy

Spokemead has an effective grievance and whistle blowing policy in place to manage any concerns within the business or its supply chain. These policies are reviewed annually to ensure that they are fit for purpose. All new and existing Spokemead employees are provided with, and have access to, a copy of the latest whistleblowing policy.

OUR SUPPLY CHAINS

At Spokemead, we recognise that our supply chain is critical to our success. We therefore seek to build lasting relationships, treating our suppliers fairly and paying promptly. We want to work with suppliers who share our values and support us in delivering our purpose. We are committed to working with our supply chain to ensure that together we can achieve wider social, economic and environmental benefits.
We use a variety of methods to undertake due diligence on each of our suppliers and ensure that we work with organisations who share our commitment to the highest possible business and ethical standards. This allows us to make informed decisions about who we want to work with. Where we are satisfied that it is a supplier that we want to engage with, we then negotiate appropriate terms with them. To the extent that our suppliers do not adhere to our standards, there can be material consequences, including the termination of our relationship with them.
Spokemead assesses compliance within its existing supply chain and will assess any new suppliers for compliance with the following criteria:

  • No forced labour or human trafficking is practiced, and employment is freely chosen;
  • Working conditions are safe and hygienic;
  • Working hours are not excessive;
  • A fair wage is paid;
  • No harsh, cruel or degrading practices are allowed; and
  • No discrimination is practised.

A failure to comply with the above is an absolute bar to pre-qualification as a supplier to Spokemead.

TRAINING, RECRUITMENT & COMMUNICATION

To make employees aware of the Act and the drivers of modern slavery, as well as the possible indicators, we share this statement with all employees through our internal communication channels and a copy of this statement is available on the Spokemead website (https://spokemead.co.uk/modern-slavery-act/com).

Spokemead is in the process of introducing a companywide intranet which will be used to facilitate modern slavery and human trafficking training/which will be used to provide employees with more detailed information on modern slavery and human trafficking.

Spokemead undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK on all employees prior to commencing employment with the Spokemead.

As part of the onboarding process for joining Spokemead, each employee is given an overview of the essential policies and information in relation to those policies, procedures and other matters such as whistle blowing.

KEY PERFORMANCE INDICATORS (“KPIs”)

Consideration is currently being given to the key performance indicators that Spokemead may choose to use in tracking our progress in reducing modern slavery risks. The indicators we choose will help to deliver an increase in awareness, especially within our key supply chains and amongst site operative teams.
These key performance indicators are likely to include modern slavery and human trafficking rates amongst our employee base.

David Bullen
Chief Executive Officer, Spokemead plc