Modern Slavery Statement: for Financial Year 2019/20
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that T Brown Group Holdings (‘Parent Company’) and T Brown Group Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. T Brown Group has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
1. OUR BUSINESS:
T Brown Group is a Private Limited Company incorporated in England and Wales with registered number 1006630. The Registered Office is at 24 High Street, Ewell, Surrey, KT17 1SJ. T Brown Group is a professional facilities services firm providing repair, maintenance and installation and building works to a number of local authorities and social housing landlords. T Brown Group has offices in England and Wales only, with no international offices or presence. T Brown Group are opposed to all kinds of slavery and human trafficking in our direct and indirect operations, and our supply chain as a whole.
T Brown Group are regulated and / or accredited by various professional bodies including:
- Gas Safe
- The Environment Agency
- Contractors’ Health and Safety Assessment Scheme (CHAS)
- Information Commissioner’s Office
- Electrical Contractors Association
- TrustMark Accreditation
The services T Brown Group provides to its clients are predominantly site or office-based (sites and offices being located in the UK only). The T Brown Group Limited supply chain, in relation to services, consists, on the whole, of other regulated or professional services. T Brown Group Limited considers these to be very low risk in relation to slavery and human trafficking, so takes no specific action in relation to these associations. T Brown Group’s Code of Conduct sets out the behaviour we expect from employees in their dealings with colleagues, customers, suppliers, agents and intermediaries. All employees and suppliers are expected to act with integrity and in accordance with the standards of behaviour set out in the Code of Conduct.
The majority of other services supplied to T Brown Group are professional services associated with running a limited company, for example banking, auditing, insurance and professional consultancy services. T Brown Group vets its external contractors, related to the industry, to ensure they have the requisite accreditations and are appropriately qualified for the roles they are asked to undertake. These services are again UK based and T Brown Group considers them lower risk areas of activity and so takes no additional steps over and above our supplier approval process.
Given what T Brown Group understands to be a low risk profile of anyone supplying us with services being involved in slavery and/or human trafficking, we believe our current procedures and ability to rely on regulatory oversight in relation to professional services, are sufficient in this regard. Given this low risk profile, no specific training is provided or undertaken by our staff in relation to these matters.
In terms of goods supplied to T Brown Group, the majority of goods will be for use in an on-site, or office environment. Occasionally T Brown Group will be supplied with goods for use outside an office environment, for example “personal protective equipment”.
Given what T Brown Group understands to be a low risk profile of suppliers of goods, no specific training is provided or undertaken by T Brown Group staff in relation to these matters. However, T Brown Group does have a number of relevant polices that demonstrates our commitment to act with integrity and ensure that there is no slavery or human trafficking part of the business, namely the following:
- Code of Conduct
- Intercultural Code of Conduct
- Environmental Policy Statement
- Health and Safety Policy Statement
- Equality, Diversity Policy Statement
- Corporate Social Responsibility Policy
- Communications Policy
- Sustainability Policy
- Monitoring policy for Racial Equality
4. OUR PERFORMANCE INDICATORS:
We do not have key performance indicators specifically in relation to slavery or human trafficking as any instance would be expected to be a non-compliance and breach of employment laws, our direct employment practices, Code of Conduct and/or Supplier Standards. However, 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:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified
5. APPROVAL FOR THIS STATEMENT:
This statement was approved by the Board of Directors on 01 April 2019