ELLIOTT GROUP SLAVERY AND HUMAN TRAFFICKING COMPLIANCE STATEMENT – MAY 2021
SLAVERY AND HUMAN TRAFFICKING COMPLIANCE STATEMENT
Consistent with our commitment to operate our business in an ethical manner and in compliance with all applicable laws and regulations, Elliott Group Limited (“Elliott” “we” or “our”) is committed to improving our practices to combat modern slavery and human trafficking in our supply chains. Whilst we have already taken positive steps to comply with these principles, we continue to work with our suppliers and employees to ensure that modern slavery and human trafficking do not take place within our supply chains or our business.
Elliott is a provider of relocatable accommodation including portable cabins, modular buildings, permanent buildings, secure storage, portable toilets, temporary fencing and related products and services in the UK.
Elliott provides modular buildings for sale and rent, and off-site permanent buildings for sale throughout the UK for temporary, semi permanent and permanent use across a wide range of sectors. Elliott has its head office in Peterborough and operates its business from a network of branches throughout England, Scotland and Wales.
Elliott is part of the Modulaire Group (“Modulaire”) which has over 4,000 employees and operates in 25 countries worldwide. Our ultimate parent company is Modulaire Holding S.à r.l. Further details about Modulaire and its operations can be found at https://www.modulairegroup.com/
OUR SUPPLY CHAINS
Our supply chains include: the manufacture of modular units; materials for buildings including steel components, walls, panels, insulation, electrical components, plumbing supplies and flooring; sub-contract services for certain delivery, installation, disassembly and repair/maintenance work; IT and other business support services.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all of our business relationships. We continue to further that commitment by implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place at any level of our supply chains.
The UK Managing Director is responsible for ensuring compliance with anti-modern slavery and human trafficking policies, within the UK operations.
This statement underpins our commitment to the UN Global Compact Principles (Human Rights, Labour, Environment and Anti-Corruption), the UN Sustainable Development Goals and any applicable local legislation.
DUE DILIGENCE PROCESS FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk, we vet the vendors that form our supply chain by way of assessing where those vendors are located and the sectors they operate in.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains;
- Mitigate the risk of slavery and human trafficking occurring in our supply chains;
- Monitor potential risk areas in our supply chains; and
- Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES
We have a zero tolerance attitude to modern slavery and human trafficking. To ensure that all those in our supply chains and our contractors comply with our values, we require vendors to adhere to our Supplier Code of Conduct, including a commitment to not use slave labour or participate in human trafficking. In addition, we seek express acknowledgement of adherence at the stage of on-boarding our suppliers/contractors.
OUR EFFECTIVENESS IN COMBATING MODERN SLAVERY AND HUMAN TRAFFICKING
We have brought this statement to the attention of those in our procurement organisation and given them the opportunity to provide feedback, raise queries and have such queries answered. We have also involved our Legal and Procurement teams in undertaking a further assessment of the risk of non-compliance in our supply
RECRUITMENT AND EMPLOYMENT
Elliott has appropriate recruitment processes and procedures in place, including conducting eligibility to work checks for all employees, to mitigate against human trafficking or forced labour. The majority of our colleagues are employed on permanent or fixed term contracts, however, when temporary staff are needed, Elliott only uses reputable employment agencies.
REPORTING KNOWLEDGE OR SUSPICION OF SLAVERY OR HUMAN TRAFFICKING
We recognise that grievance mechanisms are vital for workers to be able to raise issues through our Speak-Up Policy (whistle blowing). Our standard supplier contractual terms include obligations on performing Modern Slavery Act risk assessments, controls, and notification of modern slavery findings. Our supplier and service provider contracts include strong obligations regarding compliance with modern slavery legislation.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff with direct responsibility for our supply chain and will continue to provide this training to relevant new employees in our organisation.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2020.
Group General Counsel
Elliott Group Limited
A Modulaire Group Company