This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year.

Modern Slavery is a term which encompasses slavery, servitude and forced or compulsory labour. Human trafficking is defined as arranging or facilitating the travel of another person with a view to that person being exploited. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

This statement sets out the steps that all companies within the Emtec Group have taken during the previous 12 months to ensure that modern slavery and human trafficking is not occurring in our organisation or in our supply chains.

‍Organisational Structure and Activities‍

The Emtec Group of companies is made up of the following trading companies:

• Emtec Building Services
• Emtec Building Services (North)
• Emtec Core & Protect
• Emtec Energy
• Emtec Facility Services
• Emtec Fire Systems
• Emtec Group Management
• Emtec Property Services

Supply Chain Structure and Activities

Our trading activities are focused within the UK. Any company on our preferred supplier list are obliged to complete a Supplier or Sub Contractors Compliance Form which includes questions covering modern slavery.

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Due Diligence

The company directors and senior management shall take responsibility for implementing this policy and its objectives and shall provide adequate resources (training etc) and investment to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains.

• The Emtec Group has put in place a fair and transparent recruitment and resourcing procedure in relation to labour practices, false employment and modern slavery in accordance with relevant legislation and standards.
• The Emtec Group expects all suppliers to conduct right to work checks of their workforce in accordance with the Immigration, Asylum and Nationality Act 2006, which will be in reinforced when a worker attends their induction where papers will be verified.
• The Emtec Group seeks to work in partnership with all suppliers to tackle and combat the threat of human trafficking and modern-day slavery across the construction industry and throughout our supply chain, in accordance with international environmental, social and ethical standards.
• The Emtec Group have a clear whistle blowing integrity line policy, which provides a path for employees and suppliers to report any suspected legal or ethical breaches anonymously.
• In order to ensure the highest level of understanding of the risks associated with modern slavery and human trafficking in our supply chains, Emtec provides training for all relevant staff members.

Risk Assessment

• Our policies, listed below, require our suppliers and sub-contractors to complete an assessment to confirm that they comply with Emtec zero tolerance policy.
• Our standard contractual terms have been updated to include compliance from our suppliers and subcontractors with our Modern Slavery and Human Trafficking Policy.
• We have issued a Group wide policy confirming our zero tolerance of modern slavery and human trafficking.
• We undertake proof of eligibility checks to work legally in the UK.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

• Modern Slavery policy
• Recruitment policy
• Procurement policy
• Supplier code of conduct
• Employee code of conduct
• Grievance and whistle-blowing policies
• Training policy

Training

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 relevant members of staff. All Directors have been briefed on the subject.

Our Effectiveness in Combating Slavery and Human Trafficking

We take a proactive approach to combatting slavery and human trafficking within our business and supply chain. We employ various strategies to ensure effectiveness in our efforts:

Departmental Company Audits: Regular audits conducted by our internal auditor to ensure that procedures are followed to capture and identify risks of modern slavery.

Communication and Engagement: We maintain open communication and personal contact with all links in our supply chain, ensuring their understanding of and compliance with our anti-slavery expectations.

Scotland Against Modern Slavery Partners: We regularly participate in partner meetings alongside other businesses and key speakers to address the issue of modern slavery and collaborate on effective solutions. By actively participating in these initiatives, we aim to stay informed about the latest developments, exchange knowledge with industry peers, and contribute to the broader efforts to eradicate modern slavery from our communities and supply chains.

This statement has been approved by the company’s Board of Directors.

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