Modern Slavery and Human Trafficking Statement 2018
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.
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 our business dealings. Accordingly, Arc takes a zero-tolerance approach to modern slavery and human trafficking and 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 of Arc and signed by Dan Maher, Managing Director.
Structure, business and supply chains
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 Nottinghamshire County Council and other third party clients. This business supports a number of key strategies and plans both within Scape Group and Nottinghamshire County Council
Policies relevant to slavery and human trafficking
Arc, as part of the Scape Group of companies, adheres to and abides by a number of group-wide internal policies with the aim of ensuring it continues to conduct business in an ethical and transparent manner:
Corporate Social Responsibility Statement: Through this statement, Arc, 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
Equalities Action Plan: The Plan expounds a commitment to treating people fairly, prioritising work life balance and an inclusive recruitment and selection policy
Code of Conduct: The Code of Conduct makes clear the expectation Scape Group, including Arc, place on their 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.
Anti-Slavery and Human Trafficking Policy: This policy specifically prohibits activities linked to slavery, servitude, forced labour and human trafficking and sets out exactly what is expected of all staff within the Scape Group and supply chain in order to prevent it.
Whistleblowing Policy: The Scape Group encourages all its employees to report any concerns related to its activities or those of its contractors and supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Due diligence and steps to assess and manage the risk of slavery and human trafficking in our business and supply chains
We have undertaken risk assessments of slavery and human trafficking within our own operations as well as those of our contractors and supply chains and seek to continue to develop systems and processes to mitigate any risks we perceive.
Since our services and the resulting construction activities take place largely in the UK, we consider the risk very low and we currently have no activities (nor are we aware of any activities on the part of our contractor supply chains) in areas deemed to be of high or medium risk.
In respect of our own operations, we considered the location of our activities, the roles being performed, the recruitment processes and the absence to date of reports of concerns regarding slavery and human trafficking. We also undertake “right to work” checks on all our employees prior to them commencing their role. 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, we deem the risk of human trafficking within our own staff (including agency and contract staff under our direct supervision) to be minimal.
As for our contractor supply chains, again these are almost exclusively UK-based operations, which lessens this risk. We conduct due diligence on all our contractors and suppliers as part of our tendering exercises.
Furthermore, Arc’s framework procurements are governed by the Public Contracts Regulations 2015 and Arc uses the standard supplier questionnaire, PAS 91, to ensure responsible and compliant procurement. Although the MSA is not covered in PAS 91, we do ask 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. Our assessment of a bidder’s response considers the information they provide in respect of compliance and the procedures they have in place to meet the requirements under the MSA.
As part of our major contracting arrangements, robust and effective contractual clauses are included to address slavery and human trafficking in the supply chain.
We regularly carry out annual audits on all our 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. Any weaknesses or other concerns which are identified will be discussed with the contractor and, if necessary, remedial action will be taken.
As part of the Scape Group, we also support the work and initiatives of the Gangmasters & Labour Abuse Authority (“GLAA”) Construction Forum protocol and are fully behind the Forum’s work tackling modern slavery in construction chains.
Going forward, we plan to provide a training programme for current and new staff (as part of our induction programme) on a range of topics, including issues relating to modern slavery and human trafficking and compliance matters.
Our performance indicators
We intend to adopt a continuous improvement approach to our performance in this area.
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
any reports or concerns regarding slavery or human trafficking in our operations or supply chains are identified;
staff training on the MSA has not been completed, primarily by those in key roles to identify and address potential modern slavery risks including Human Resources, Legal and Procurement functions, by the target date.