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 business, which offers engineering, construction, demolition, decommissioning, remediation, rail, environmental services and reinforced concrete structure solutions. The company is a key player in developing and maintaining Britain’s built environment and operates in highly regulated environments; making sites ready for new infrastructure and developments.

We have implemented policies and procedures to ensure fair and ethical treatment, these include;

  • Equal opportunities and anti-discrimination
  • Training and Development
  • Health and Safety
  • Fair pay
  • Whistle-blowing

Supply Chain

Our supply chain is predominantly made up of organisations utilised across our Specialist Contracting 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.

Risk

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. In addition, 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 are committed to auditing the recruitment agencies we utilise across a range of topics including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence.

We acknowledge that further work is required with our wider supply chain to confirm modern slavery requirements are in place and this will be developed following the recruitment agency exercise.

Training

We have previously provided training to our people on equality and diversity but we acknowledge that the process needs to be more robust both in content and coverage of employees.

In 2019 we will be enhancing our training to include modules on modern slavery, corporate social responsibility, and fairness, inclusion and respect. We will be introducing an inclusion roll out programme which will mandate training on modern slavery across the Group.

John Keehan
Group Deputy CEO
Date: April 2019

Annex

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:

  • Keltbray Limited
  • Keltbray Aspire Limited
  • Keltbray Group Limited
  • Keltbray Plant Limited
  • Keltbray Structures Limited