Keltbray Group (Holdings) Limited incorporates organisations that make up the Keltbray Group of companies. These organisations are listed at the end of this statement.
Keltbray Group (Holdings) Limited (referred to as Keltbray Group herein), is a UK leading specialist engineering and construction business, which provides engineering, construction, demolition, decommissioning, remediation, environmental services, reinforced concrete structures, rail and power distribution and transmission solutions to public and private sector clients. In the main these services are provided on a self-delivery basis. The Group is a key player in developing and maintaining Britain’s built environment and infrastructure, and operates in highly regulated environments.
We have implemented policies and procedures to ensure fair and ethical treatment, these include;
Our external supply chain is predominantly made up of organisations utilised across our Built Environment Services and Infrastructure and Rail divisions. We directly contract these organisations to complete work on our behalf or supply materials or labour.
The Keltbray Group due diligence process for suppliers incorporates a review of the controls undertaken by the supplier. All organisations that the company deals with are required to confirm that both they and their supply chain are not knowingly involved in slavery and human trafficking. Such a declaration is required by all companies in order to be added to the company’s preferred supplier list.
Where we have most control, in respect of modern slavery and human trafficking, is in recruitment of direct employees. We have procedures in place to ensure that recruitment is completed in line with regulatory requirements and our people have access to rights and appropriate conditions. We view this area as low risk.
The highest risk to Keltbray Group is through our temporary staff whom are recruited via recruitment agencies. Our recruitment process conforms to regulatory requirements and the fair and ethical treatment of temporary employees.
Previously all agencies have been required to confirm on an annual basis that they are not involved in slavery or human trafficking. During 2018 we completed a desktop review of the policies and practices undertaken by the recruitment agencies to confirm they were compliant with requirements for modern slavery and payment of wages. From these reviews there have been no signs of modern slavery.
In 2019 we improved our process for reviewing recruitment agencies by auditing them across a range of topics, including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence. The audits highlighted minor issues however none of these were related to modern slavery. Feedback was provided to the recruitment agencies to assist them in improving their systems and processes.
Going forward, we will periodically audit our roster of recruitment agencies as part of a continuous improvement process.
We acknowledge that further work is required with our wider supply chain as part of our approach to risk management and mitigation to confirm modern slavery requirements are in place. We will aim to include a review of modern slavery in the audits of suppliers and sub-contractors during 2020.
Finally, we have identified that our whistleblowing policy warrants improvement. We recognise that Keltbray employees are valuable and often the first to witness any type of wrongdoing. The information they may uncover could prevent wrongdoing and even help people in need. We will update the policy to make it consistent with Keltbray’s open and supportive culture. We will also review training requirements to confirm appropriate support is available.
In 2019 we introduced the training modules for modern slavery, corporate social responsibility, and fairness and inclusion. The modules were made available for voluntary completion as part of the Keltbray Learning and Development package.
In 2020 further enhancements have been made to the modern slavery training, including guidance on ‘right to work’ checks. Furthermore, we will be introducing a roll out programme which will mandate training on modern slavery across the Keltbray Group.
Group Chief Operating Officer
Date: April 2020
Subsidiary companies of Keltbray Group (Holdings) Limited meeting the criteria to require the preparation of an annual slavery and human trafficking statement, in accordance with the Modern Slavery Act 2015, that are included within the scope of this statement: