1. POLICY STATEMENT
Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or 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 are committed to improving our practices to combat slavery and human trafficking
Generation has a zero-tolerance approach to modern slavery in any of its forms and welcomes the implementation of s.54 Modern Slavery Act 2015 and we are committed 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.
This statement 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, suppliers or any other people or bodies associated with the business.
2. COMPANY OVERVIEW
Generation was formed in 1978 as part of the McAlpine construction group, before being sold to the Mitie Group PLC in 1997. In 2004 it became an independent company after a management buy out headed by existing Managing Director, Mark Clifford, and Commercial and Finance Director, Alan Wilkinson.
In 2012 it became part of the Altrad Group, an international leader in the provision of industrial services (principally to the energy and natural resources sectors), and in the manufacturing of construction equipment and material.
3. RESPONSIBILITY FOR THE POLICY
The Board of Directors has overall responsibility for ensuring this policy complies with our legal obligations, and that all those under our control comply with it.
The Modern Slavery Policy Compliance Team (the ‘Compliance Team’) which comprises the Managing Director, Financial Director and Divisional Directors will work together to ensure that this policy is maintained across all operational areas of the Business in accordance with evolving regulatory requirements and to ensure that any breaches or concerns are addressed.
The Managing Director has primary and day-to-day responsibility in relation to our supply chain for implementing this policy and monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
The Divisional Directors have primary and day-to-day responsibility in relation to those directly employed by us for implementing this policy and monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
4. COMPLIANCE WITH THE POLICY
All persons working for Generation must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. All persons working for Generation are required to avoid any activity that might lead to, or suggest, a breach of this policy.
All persons working for Generation are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier at the earliest possible stage, by reporting it in accordance with our Whistleblowing Procedure.
5. COMMUNICATION AND AWARENESS OF THIS POLICY
This policy will be communicated to all Generation employees.
Generation employees are required to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce our approach as appropriate thereafter.
6. DUE DILIGENCE
In order to give effect to our zero-tolerance approach, we have systems in place to ensure that all employees and those in our supply chain implement our policy. These will be kept under review by the Compliance Team.
7. BREACHES OF THIS POLICY
Any breach of this policy will generally be treated as gross misconduct and may result in dismissal without notice. We may terminate our relationship with individuals and organisations working on our behalf if they do not comply with this policy.
Signed on 31 August 2019 by :-
Mark Clifford – Managing Director