Anti-Slavery and Human Trafficking Statement
2022
This Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) relating to Transparency in Supply Chains. AmeyBriggs Services Ltd, (AB) recognises that it has a responsibility to take a robust approach to slavery and human trafficking and indeed takes a zero-tolerance approach to non-compliance with the Act in any part of its business or its supply chain. This sets out the steps AB has continued to take to address the risk of slavery and human trafficking within its operations and supply chain.
Organisational Structure
AB is a joint venture between infrastructure support service provider Amey Plc and Briggs Equipment UK Ltd, a specialist provider of asset management and engineering services. AB employs circa 150 personnel and operates mainly in the UK. In addition, AB supports permanent fleets in Kenya, Canada, Falkland Islands and Cyprus, and equipment can be deployed worldwide in support of UK military operations and training. AB’s head office is in London.
Our Business
AB is a provider of construction and mechanical handling equipment to the UK Ministry of Defence (MoD).
AB secured the MITER contract to maintain and manage the Ministry of Defence’s (MOD) fleet of construction and materials handling equipment, and other key plant, until 2027.
MITER is an important MOD contract involving the deployment and maintenance of key equipment used by the UK’s Armed Forces around the world as well as supporting military personnel in how to use it. The seven-year contract is valued at £240m and supports the MOD’s requirement to ensure a sustained and consistent service for the British Armed Forces personnel on deployed operations at home and overseas.
Vehicles in the MITER fleet include excavators, bulldozers, cranes, and forklift trucks and meet Defence’s need for earth-moving, engineer construction and mechanical handling capabilities.
Our Governance for Modern Slavery
The AB Board has overall responsibility of our approach to Modern Day Slavery. AB manages and detail business risk register including actions to help reduce the risk of modern slavery occurring within our operations and our supply chain.
Our Policy on Slavery & Human Trafficking
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero- tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Our policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
AB has an effective grievance and whistle blowing process and policy in place to manage and investigate any concerns within the business or the supply chain. All new AB employees are provided with, and have access to, a copy of our values. Information on this is also included as part of the employee induction process.
Our Supply Chains
AB’s supply chains include:
- Plant, vehicles and equipment suppliers
- Subcontractors and various service providers
- Manufacturers and suppliers of goods and materials
All procurement of services and supplies is undertaken by professional procurement specialists within our team. AB strives to build and maintain long term sustainable relationships with its suppliers encouraging collaborative working and exchange of innovative and good industry practices. As part of the supply chain process, AB has a number of systems to:
- Evaluate new suppliers as part of the on-boarding process
- Identify and assess potential risk areas in our supply chains and
- Monitor potential risk areas in our supply chains
AB assesses compliance within its existing supply chain and will assess any new suppliers for compliance with our Anti-Slavery and Human Trafficking Policy. A failure to comply with the above is an absolute bar to pre-qualification as a supplier to the AB Group.
Supply Chain Risk
AB reviews its supply chain Modern Slavery risk at each annual review with suppliers. The review assesses both the risk of Modern Slavery occurring and the strategic risk to AB with the emphasis on those categories considered most at risk. The following procurement categories are considered to be of highest risk of modern slavery occurring:
- Parts and consumables
- Equipment manufacture
- Waste Disposal
Recruitment & Training
AB undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK on all employees prior to commencing employment. These checks include a regular ongoing review of bank account, next of kin and home address duplications, as potential indicators of Modern Slavery. Where duplications are identified these are followed up by out HR team and line managers. As part of the onboarding process for joining each employee is given an overview of the essential policies and information in relation to those policies, procedures and other matters such as whistle blowing. AB uses web-based training, accessible to its employees. We have developed a centralised dashboard to provide visibility to our managers on employee training completion.
Key Performance Indicators (KPIs)
AB’s measures to combat Modern Slavery undergo constant review and the pro-active regime of training and internal and external audits. The main KPIs for ensuring the effectiveness of reducing the risk of slavery and human trafficking include:
- Employee completion of Modern Slavery e-learning
- Screening for duplications in employee data as a potential indicator of modern slavery (next of kin, bank details, bank addresses)
- Actual and potential incidents raised through any of the channels provided
AB will complete the Government’s Modern Slavery Assessment Tool for the first time in 2023.
In 2023, AB will progress the following actions:
Continue to raise the awareness of Modern Slavery to our employees and our suppliers. Complete the Modern Slavery risk mapping assessment to help inform our auditing programme. Continue to strengthen its approach to supplier engagement and compliance on Modern Slavery. Collaborate with industry partners and parent companies to ensure best practice is being applied.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes AB’s slavery and human trafficking statement for the financial year ending 31 December 2022. This statement applies to AmeyBriggs Services Ltd.