Modern Slavery and Human Trafficking Statement 2023
This statement is made pursuant to S.54 of the Modern Slavery Act 2015 (“the MSA”) and sets out the steps taken by Arc Property Services Partnership Limited (“Arc”) to prevent modern slavery and human trafficking in its business and supply chains for the financial year ending 31st March 2023.
Arc’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 its business dealings. Accordingly, Arc 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 and signed by Dan Maher, Managing Director.
Arc Property Services Partnership Limited, trading as Arc Partnership, is a Joint Venture Company, formed by Nottinghamshire County Council (NCC) and Scape Group (SG) on 1 June 2016, focussed upon the delivery of property design, programme management, planned and reactive maintenance services to NCC. This is an exclusive 10-year Service Contract (2016-2026), with the potential for a 5-year extension through to 2031.
Arc Partnership, as a subsidiary of Scape Group, is one of a number of Local Authority controlled companies that deliver a wide range of innovative services focused upon quality of outcome, value for money, and customer excellence for NCC and other third-party clients. This business supports a number of key strategies and plans both within Scape Group and NCC.
SCAPE operates a number of internal policies with a view to ensuring that it is conducting business in an ethical and transparent manner. Arc Partnership adheres to and abides by these policies.
In 2022/23 SCAPE undertook a review of its policies and procedures in relation to how modern slavery and labour exploitation is addressed. Nine policy and guidance documents were reviewed.
Relevant policies include:
- Corporate Social Responsibility Statement: Through this statement, Arc Partnership, as part of the Scape Group, 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.
- Code of Conduct: The Code of Conduct makes clear the expectation Scape Group, including Arc Partnership, places on its employees to maintain the highest standards of conduct and behaviour when representing the organisation; the Code also covering policies relating to the avoidance of conflicts of interest, impartiality, hospitality, political neutrality and whistleblowing.
- Statement of Ethics: This clearly demonstrates the Group’s pride in its reputation for acting fairly and ethically in doing business and the values, commitment, and integrity of its employees; the statement also covers its policy relating to anti-bribery and corruption.
- Modern Slavery and Ethical Labour Policy: In conducting its business activities Scape Group seeks to uphold, preserve and promote the rights of all workers within its supply chain, taking all measures it can to reduce the risk of modern slavery and any other forms of labour exploitation.
Due diligence and steps to assess and manage the risk of slavery and human trafficking in our business and supply chains.
In respect of its own operations, Arc Partnership considered the location of its activities, the roles being performed, the recruitment processes and the absence to date of reports of concerns regarding slavery and human trafficking.
Arc Partnership undertakes “right to work” checks on all its employees prior to their commencement of work. 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, Arc Partnership deems the risk of human trafficking within its own staff (including agency and contract staff under its direct supervision) to be minimal.
Arc Partnership recognised that the risks within its own supply chain for goods and services needed to be assessed and a modern slavery risk assessment was undertaken in 2022/23. The findings within this assessment will be included within the review of the Group Procurement Policy, which will supplement the policy review already conducted. This will include a review of the due diligence process.
Arc Partnership conducts due diligence on all its contractors and suppliers as part of its tendering exercises. This has not identified any issues of concern during the reporting period.
Arc Partnership’s framework procurements are governed by the Public Contracts Regulations 2015 and utilises a standard selection questionnaire. This includes 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.
Arc Partnership’s assessment of a bidder’s response considers the information provided in respect of compliance and the procedures they have in place to meet the requirements under the MSA.
Through the requirements of the SCAPE Framework, major contracting arrangements utilised by Arc Partnership include contractual clauses to address slavery and human trafficking in the supply chain.
Arc Partnership carries out a representative selection of annual audits on all its 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. If Arc Partnership suspects that a contractor or supplier may have been in breach of its requirements and expectations with regard to the use of slave or bonded labour, it will report this to the GLAA who will take any appropriate action or offer further guidance.
In addition to the above, SCAPE will provide additional specialist audit support as required and provide an agreed number of Achilles Modern Slavery Management System Audits, to align with the work being done by the SCAPE Modern Slavery Strategic Partnership.
To date Arc Partnership has adopted a continuous improvement approach to its performance in this area, this will continue.
However, the modern slavery risk assessment has identified that there are several service providers which fall into high and medium risk categories for labour exploitation. Arc Partnership will consider steps to reduce the number of high and medium risk suppliers where it is practical to do so.
In 2023/24 Arc will ensure that all employees within project management and commercial roles undertake the modern slavery training though the Learning Management System and are made aware of Scape Group’s approach to modern slavery and the policies and procedures which apply.
In addition, SCAPE is in dialogue with the Supply Chain Sustainability School in order to develop a learning pathway to provide additional training for key roles, these will include Procurement, Contract Managers and Framework Managers. This may be extended to Arc Partnership as an addition to the mandated module in due course.
Responsibility for compliance
The Managing Director is responsible for the company’s compliance with the Scape Group Anti-Slavery and Human Trafficking Policy and the MSA. The Managing Director is advised and supported by SCAPE’s Heads of Human Resources, Procurement & Audit and Legal & Governance.
Objectives for 2023/24
The objectives for 2023/24 are set out below.
These incorporate activities across Scape Group and its operations where appropriate.
Arc Partnership will:
- Support the development of the Group Procurement Policy for suppliers of goods and services.
- Consider steps to reduce the number of high and medium risk suppliers where it is practical to do so.
- Ensure that all employees within project management and commercial roles undertake the modern slavery training through the Learning Management System and are made aware of Scape Group’s approach to modern slavery and the policies and procedures which apply.
- Undertake at least four independent audits of contractors/suppliers involved in Arc Partnership projects.
- Develop a programme for, and undertake, additional audits through the SCAPE Frameworks Audit Team. The scope for this being determined on a supplier-by-supplier basis.
This statement was approved by the Board of Directors of Arc Property Services Partnership Limited on 1st August 2023.
Arc Property Services Partnership Limited