Modern slavery

Our business is built upon a culture of robustness and performance, which is underpinned by an individual and collective commitment to maintain the highest ethical standards at all times. We recognise that we have a responsibility to take a robust approach to tackling modern slavery, and our organisation is committed to ensuring that our supply chains are free from slavery and human trafficking.

About Equans Specialist Contracting UK Limited

Equans Specialist Contracting UK Limited (“ESC”) is a part of the Equans group of companies under the ownership and control of Equans S.A.S. Equans S.A.S is part of the Bouygues group of companies under the ownership and control of Bouygues S.A.   

ESC defines, designs and delivers across all aspects of its clients’ mission-critical environments. ESC provides a complete, integrated solution to bring clients’ vital strategic facilities to life. Starting with setting business goals and outcomes, ESC works across every aspect—from design and build, to assurance, validation, handover and ongoing lifecycle optimisation. ESC does this as a complete and assured partner, bringing certainty of delivery to every step, with precise, cohesive focus in every area at each stage, and the agility to integrate everything at every point.  

Modern Slavery Policy

Our Modern Slavery Policy and procedures support Equans’ global ‘fundamentals’ - the common framework and ways of working that provide the basis for how we manage and operate across our entire business.

This policy sets out the commitments of ESC in relation to modern slavery. This policy applies to employees at all levels, directors, officers, temporary agency workers, seconded workers, volunteers, agents, suppliers, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and ESC may review and amend this policy at any time. It will be reviewed on a regular basis to ensure it complies with relevant UK legislation.

Changes to this policy will be notified by publishing the updated version on ESC’s intranet site.

1.       Purpose

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms as shown below, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. ESC will raise awareness of modern slavery and our expectations of what should be done to address any issues or suspicions, through this policy and associated training.

There are a number of crimes that are covered under the definition of modern slavery. These are:

• Bonded labour – individuals who are forced into debt by paying to get a job or mandatory equipment or have their passports taken to restrict their movements.

• Forced labour – individuals who are forced to work long hours for little or no pay in poor conditions, under verbal or physical threats to themselves or their families.

• Trafficking – individuals or groups moved from one area to another for forced or bonded practices.

• Criminal exploitation – where a victim is exploited to commit a crime, for example, pickpocketing, shoplifting, drug trafficking and cannabis cultivation.

• Sexual exploitation – including sexual abuse, forced prostitution and abuse of children for the production of images or videos.

• Domestic servitude – where an individual is forced to work in private households with restricted freedom and work long hours for little or no pay.

Less commonly identified crimes include organ removal, forced marriage and illegal adoption.

2.       Aim

ESC has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensuring modern slavery is not taking place anywhere in our own business or our supply chain.

In our supply chain, we ask our suppliers to implement due diligence for their own suppliers and subcontractors to ensure there is no slavery or human trafficking in their supply chain.

As an equal opportunities employer, we are committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all employees to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective and current employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

ESC takes a strict approach to acts, actions and behaviours deemed to be in breach of this policy statement, and any such incidents will be dealt with in accordance with the applicable disciplinary procedure. Breaches of this policy statement may amount to gross misconduct resulting in summary dismissal.

ESC may terminate its relationships with other individuals and organisations if they are believed to have breached this policy.

3.       Responsibilities

ESC

• Actively works to ensure that risk of modern slavery within its own business activities, and that of its supply chain, is minimised and will adhere to the requirements of all relevant local and national laws.

• Ensures our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of a business relationship and is reinforced as appropriate thereafter.

• Provides employees and managers with appropriate information and training in order to ensure effective communication and understanding of, and compliance with, this policy.

• Prohibits employees at all levels, directors, officers and representatives of the business making threats of violence, harassment or intimidation, committing acts of discrimination and confiscating workers original identification documents.

• Prohibits child labour and the use of worker-paid recruitment fees.

• Ensures workers have freedom of movement, freedom of association and the right to resign from their employment with the company.

• Encourages the reporting of any incidents or suspicions by all employees and is committed to taking appropriate action without undue delay.

Employees

• Must familiarise themselves with this policy and act in accordance with ESC’s commitments at all times; undertaking any training that is required of them by the company.

• Must escalate any concerns or issues they may perceive to be in breach of this policy to local management or HR swiftly and in confidence; if it doesn’t feel right, tell someone.

• Should use Equans’ whistleblowing system to report concerns in confidence if they feel they cannot talk to local management or an HR representative; email ethicsandcompliance.uk@equans.com or telephone 0333 666 5690 [callers to the whistleblowing system have the option of remaining anonymous].

• Must co-operate with managers in eliminating any risk of modern slavery and human trafficking within ESC’s own activities and supply chain.

Managers

• Have a personal responsibility for ensuring this policy is communicated, understood and applied in their business area; ensuring any relevant training is delivered to all employees within their area of responsibility as required by the company.

• Will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to have been mistaken.

• Must treat concerns raised by employees seriously; investigating and escalating as appropriate and taking any required action without undue delay.

Supply Chain

Our supply chain is made up of suppliers, subcontractors and consultants across multiple categories. They are required to sign up to the CSR and Supplier Charter which and includes requirements to commit to compliance with ESC’s ethics, anti-bribery and corruption and modern slavery and anti-discrimination standards. 

The commitments to ESC include that the supply chain organisation:

• complies with and with all applicable laws, statutes, regulations and codes including the 10 Principles of the UN Global Compact;

• conducts its business in a manner that is consistent with the Modern Slavery Act 2015 and fundamental protection of Human Rights which includes implementation of a due diligence procedure for its own supply chain to ensure that there is no forced or compulsory labour, slavery or human trafficking taking place;

• maintains fair competition and avoids complicity in its business practices; 

• ensures there is full compliance with all relevant legislation relating to equality and diversity, in particular the Equality Act 2010 and is committed to promoting equality of opportunity and diversity within the organisation and its supply chain; and 

• ensures that any concerns or non-conformities must be reported through the EQUANS Ethics & Compliance reporting system either by phoning 0333 666 5690 or emailing EthicsandCompliance.UK@equans.com

As part of the supply chain management and due diligence requirements the supply chain is committed to transparency and improvement which includes:

• Undertaking an annual assessment and participation in any quality, health and safety and environmental audits to monitor performance, as required.

• Compliance with all statutory, regulatory and ESC reporting requirements.

• Providing information on the provenance of products and being transparent in relation to identification of enterprise risks, processes and working practices

   

   

  4.       Monitoring and Review

This policy will be reviewed regularly to ensure our statements of commitment are appropriate and in line with current legislation. 

ESC will also review all other policies that may be of relevance to, or in connection with, this policy to ensure our commitments are sustained.