Modern Slavery Policy Statement

This statement has been published in accordance with section 54 of the UK Modern Slavery Act (2015). It sets out the steps taken by Maylim Limited during the financial year ending 5th April 2019 to prevent slavery, forced labour and human trafficking from taking place in any part of our own business operations, or that of our supply chain.

From here on in Maylim Limited will be referred to as ‘Maylim’ or ‘the Company’.

Introduction

Maylim is committed to conducting business honestly and with integrity, both in terms of our operations and the respect and value we have for our workforce and partnerships. Maylim strive to treat all people with dignity and have developed and adopted a proactive approach in deterring, identifying, and tackling hidden labour exploitation. Maylim do not tolerate any kind of forced labour, child labour or exploitation. Our intention is to encourage awareness of the issues around modern slavery, and ensure early identification of issues or concerns of human trafficking and forced labour, in line with the guidance set out in the Modern Slavery Act (2015).

Organisation Structure and Supply Chains

Maylim work across both public and private sectors to deliver high quality external works and hard landscaping, as well as highway and civil engineering projects. The Company carries out work either as a principal contractor working directly for a client, or as a first-tier contractor under a principal contractor. Maylim employ a number of its workforce directly, but also use regular contract labour and will sub-contract work packages to other companies where applicable. Our subcontractors supply their own labour to work for Maylim.

Maylim has a diverse workforce and therefore employs people from a number of different countries to work on our construction sites, both directly and through our sub-contractors. There is a risk that some foreign labour could have been trafficked. It is within Maylim’s company policy to check the identity and right to work of all of our directly employed staff. It is also stated within this policy that all subcontractors and employment agencies are to conduct their own checks, in accordance with UK visas and immigration enforcement guidelines.

In addition, Maylim’s supply chain also consists of our suppliers of goods, services and materials. The majority of the materials used in our operations are procured by the Company. Where possible, there is a preference to source materials from within the United Kingdom. However, this is not always possible due to commercial availability. For this reason, Maylim’s supply chain includes some countries where there is a greater risk of modern slavery issues and child labour. In order to mitigate against this risk, Maylim only use an approved list of suppliers with an identifiable and distinct legitimate business entity.

Modern Slavery in Collaboration with Other Policies

This policy statement operates in conjunction with Maylim’s policies on Code of Conduct, Anti-Bribery, Equal Opportunities, Dignity at Work, Raising Grievances, Whistleblowing and our Ethical Policy. These policies are designed to ensure that Maylim is acting ethically and with integrity in the way that we operate as a business. Our policies frame Maylim’s standards and ethics, helping to ensure that unlawful discrimination or business practices are avoided. To ensure their effectiveness, Maylim’s policies are accessible to all employees on the company server.

Due Diligence Processes and Our Effectiveness

In the last financial year, in order to minimise this risk of modern slavery in the supply chain, Maylim has:

  • Continued to check the identity and right to work of all of our directly employed staff in accordance with UK visas and immigration enforcement guidelines;
  • Asked our suppliers and subcontractors to provide details of their own policies and procedures, in regard to the measures they are taking to ensure their workforce is eligible to work in the UK;
  • Introduced MSite across the business as part of our response to the changes in GDPR regulations. Registration on MSite is a prerequisite for any person before starting work for Maylim, this includes all agency labour and subcontractors. Proof of identity and right to work checks form part of the registration process. The MSite system allows the Company to keep a secure record of all labour across all of our sites using biometric recognition;
  • Become a member of the Supplier Ethical Data Exchange (SEDEX) platform dedicated to driving improvements in responsible business practices and increasing transparency in supply chains. SEDEX allows companies to map their supply chain and assess risks regarding labour standards, health & safety, environment and business ethics;
  • Continued to protect whistle-blowers making disclosures under our Whistleblowing Policy;
  • Remained a registered member of the Stronger Together initiative to reduce modern slavery. Maylim has continued to utilise guidance, tools and resources, to ensure we are kept up to date with best practice and legislation for how to manage the risk of modern slavery in our business and;
  • Continued to share knowledge and improve understanding of modern slavery issues amongst our workforce and across the supply chain, through our company induction; toolbox talks; posters and leaflets on site and awareness training for specific team members.

Training and Commitments for the Coming Year

  1. Maylim will continue to develop its commitment to tackling forced labour and human trafficking by developing a tiered training system to further raise awareness and educate our workforce and supply chain over the risks and prevention of modern slavery. Maylim will also ensure that improving ethical labour standards and tackling modern slavery is a fixed agenda item for discussion during meetings with labour providers, but also internally as part of Maylim’s ongoing strategic review.
  2. We have designated appropriate managers to attend formal training on ‘Tackling Modern Slavery in UK Businesses and Supply Chains’. They also hold responsibility for developing and operating company procedures relevant to this issue.
  3. All Maylim’s existing employees will undertake awareness training in recognising, preventing and reporting forced labour, labour trafficking and other hidden third-party labour exploitation.
  4. Maylim’s induction training for new workers will include the provision of training on how to recognise and report forced labour, labour trafficking and other third party hidden party labour exploitation. Maylim participates in the Stronger Together initiative and will use their resources to raise awareness and give guidance for employees on how to spot the signs that might indicate potential exploitation.
  5. Maylim will only work with contractors and suppliers (including labour providers and recruiters) that have taken part in our pre-qualification questionnaire process and are approved by us as meeting the same high ethical business standards that we adhere to.

This statement is made pursuant to section 54 of the UK Modern Slavery Act (2015) and constitutes our modern slavery and human trafficking statement for the financial year ending 2019.

Signed on behalf of Maylim Limited

Signed:

Thomas O’Mahony

Date: 19.06.2019