Modern Slavery Statement

OUR BUSINESS AND VALUES

Bennett (Construction) Limited, Bennett Construction (London) Limited and Bennett Management Contractors (GB) Limited are members of the Bennett Group, an international construction services company. Bennett operates primarily in the UK and Ireland with our Head Office based in Ireland. Bennett has approximately 200 employees.

We work closely with several suppliers and subcontractors. The majority of these businesses operate within the UK and Ireland and this statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015, setting out the steps we believe, mitigate our risk with respect to slavery and human trafficking.

POLICY STATEMENT

Modern Slavery is a serious crime, violating an individual’s fundamental rights. This statement 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 business or our supply chains. Bennett’s ‘Zero Philosophy’ is applied to everything we do at every level of our organisation. To ensure all those in our supply chain comply with our values, we require our supply chain to contractually commit to compliance with the Modern Slavery Act 2015.

Our recruitment processes are both transparent and thorough. We have robust procedures in place for vetting new employees and ensuring we can accurately confirm their identities.

Our Employee Ethics and Responsibility policy outlines our commitment to conduct our business to the highest standard, the role our employees play and the procedure for raising any issues of illegal or unethical activities.

DUE DILIGENCE

As part of our on-going commitment to comply with the Modern Slavery Act, 2015, Bennett will continue to monitor and mitigate any risks within Bennett and our supply chain.

We enforce the provisions of the Modern Slavery Act through our contractual agreements with our supply chain.

Our sub-contracts are specifically tailored to ensure enforcement of the Modern Slavery Act and any breach of the provisions of the Modern Slavery Clause will automatically lead to termination of the sub-contract. This helps to ensure that our supply chain work with us to stamp out any possibility of Modern Slavery on our sites and in the wider industry.

Our procedural controls are reinforced by our strategic procurement approach to developing preferred supplier relationships with key supply chain partners, including our temporary labour and logistics providers with whom we work repeatedly and know very well.

There is an industry wide obligation to ensure that this practice is stamped out and we try to do all in our power to play our part in the eradication of Modern Slavery across the industry.

TRAINING

All of our employees undertake compulsory training on Modern Slavery This training explains what modern slavery is and outlines the responsibility of the company and our employees to help prevent, detect and report any incidences of modern slavery.

In addition to our basic training we insist that those involved in procurement undertake additional training on Modern Slavery through the Supply Chain Sustainability School.

We deliver Toolbox Talks on our sites, briefing all site workers on what modern slavery is, awareness of the warning signs and how to report any concerns.

INTERNAL POLICIES

This Policy Statement is supported by our internal procedures which assist in ensuring that we conduct our business in a transparent manner and implement effective controls. For example, compliance with our Right to Work in the UK policy, promoting our equal opportunities policies and ensuring employees align to our Code of Conduct and Employees Ethics and Responsibility Policies. These policies implement effective systems to ensure, as far as is practical, that human trafficking and slavery are not taking place in Bennett or any of our supply chain.

SUMMARY

This statement is made pursuant to s.54(1) of the Modern Slavery Act 2015 and serves as our Modern Slavery and Human Trafficking statement for the year ending 31st March 2021.