Aztec Construction Midlands Ltd Policy Statement
Modern Slavery and Human Trafficking Statement 2024
This statement is made in accordance with the requirements of the Modern Slavery Act 2015.
Aztec Construction Midlands Ltd has and operates a zero-tolerance approach to modern slavery and is committed to working to ensure that our own operations, and those of our supply chains, are appropriately evaluating the risks of modern slavery. We are working to mitigate these risks as far as possible through our commitment to ethical business. We strive to improve our standards of ethical behaviour continuously and our commitment to ethical business practice is outlined in our Code of Conduct and accompanying Whistleblowing Policy. Our directors, and staff members are all fully committed to ensuring this outcome.
Aztec Construction Midlands Ltd has a number of policies, procedures and processes that support us to:
– Reduce the risk of slavery and human trafficking occurring in our business and supply chain;
– Provide adequate protection for whistleblowers and;
– Operate a robust supplier onboarding process.
These policies include:
– A comprehensive Code of Conduct and accompanying policy on whistleblowing.
– The Code of Conduct reminds our people that we are an organisation which acts honestly and ethically. Employees are reminded that they should report any concerns of potentially illegal activities, unethical conduct or anything that might prejudice the business either to the appropriate management or in accordance with the Whistleblower Policy.
– A whistleblowing policy which allows staff to report either through an independent Aztec Construction Midlands Ltd service to the Directors.
– Employment policies, including:
– Recruitment processes for carrying out checks on the right to work in the UK;
– Up-to-date employment contracts which comply with UK labour laws, for example, in respect of the national minimum wage, making deductions from wages, notice periods and working time;
– Equal opportunities policy;
– Anti-harassment policy; &
– Grievance procedures.
– Corporate social responsibility policies, including on health & safety and sustainability.
– Training and competence programmes for employees and subcontractors, including ensuring our employees and subcontractors have the minimum levels of qualifications required to deliver our contracts.
– Standard purchase order terms and conditions for our key suppliers, which require them to:
– Comply with the Modern Slavery Act 2015 & all other anti-slavery & human trafficking legislation; &
– Not engage in any activities constituting an infringement of the United Nations Guiding Principles on Business & Human Rights.
– A breach of anti-slavery laws by a supplier constitutes a material breach of contract and is deemed not to be remediable.
Aztec Construction Midlands Ltd.’s operational business is solely within the United Kingdom. Accordingly, we consider the geographic risk of slavery and human trafficking to be relatively low.
We are committed to acting ethically & with integrity in all of our business transactions. These two areas are addressed as follows:
Workforce – Training on modern slavery and trafficking.
– We have induction and training processes to ensure staff members are aware of the Modern Slavery Act and its definitions of slavery and human trafficking. This includes an awareness training module on our online learning portal, which is available to all members of staff. We have ensured that our on-boarding procedure and employee handbook set out our policies and procedures, including our whistleblowing policy.
Supply Chain – Due diligence processes.
– The overwhelming majority of our supply chain is based in the UK, albeit some products and components do come from overseas. We have a supplier onboarding process that seeks to ensure that our supply chain consists of organisations that have good quality controls, suitable financial standing and are compliant with UK legislation. We consider this to be an initial risk management step to ensuring our supply chain conducts itself appropriately and therefore adopts anti-slavery practices. Furthermore, our standard supplier terms and conditions for working with Aztec Construction Midlands Ltd contain specific provisions relating to the Modern Slavery Act and social responsibility.
Risk assessment and management
– We adopt tender specification requirements to set expectations of how goods and services should be delivered. Tender evaluation processes are also designed to establish whether suppliers can meet these expectations. Where possible, we award contracts to companies registered in the UK. This means that our suppliers are likely to match our levels of transparency in relation to UK employment law and the Modern Slavery Act.
– This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2024, as approved by the directors.