Keltbray Holdings Ltd and subsidiary companies* (referred to as Keltbray Group herein), incorporates organisations that make up the Keltbray Group of companies.
Keltbray has implemented policies and procedures to ensure fair and ethical treatment, these include:
Keltbray Group have signed up to the Gangmasters & Labour Abuse Authority construction protocol and we are signatories of this. It is aimed at eradicating slavery and labour exploitation in the construction industry. The construction protocol commits signatories to:
Keltbray Group undertakes its works through a combination of directly employed people and enaging the supply chain through full subcontract or temporary employment of people through recruitment agencies.
Keltbray Group external supply chain is predominantly made up of organisations utilised across our Built Environment and Infrastructure divisions. It directly contracts these organisations to complete work on its behalf or for supply of materials, labour or other services.
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 supplychain 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 and forms part of the Group’s ‘Procedure for Subcontractor & Supplier Selection’ (GRP-PROC-PRO-001)
Where Keltbray has 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.
The policy is to periodically audit our roster of recruitment agencies across a range of topics, including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence as part of a continuous improvement process and feedback is provided to the recruitment agencies to assist them in improving their systems and processes.
The Keltbray Group’s policy includes a Pre-qualification Questionnaire and on-boarding process for agencies that require the suppliers to produce documentation to confirm that they are compliant with requirements for modern slavery and payment of wages. As further risk mitigation and assurance, this information is reviewed externally by our insurers who confirm that all of the necessary standards are met for supply as a pre-requisite to contract engagement.
Training modules for modern slavery, corporate social responsibility, fairness and inclusion, and the ’right to work’ are made available for voluntary completion as part of the Keltbray Learning and Development package.
A digital learning platform that is accessible to all Keltbray people that includes learning in Modern Slavery and Equality, Diversity and Inclusion is to be available.
Keltbray and its management team fully support this policy and are committed to provide competent personnel and financial resources to implement it. This policy statement shall be reviewed at least annually by all interested parties. All Keltbray policies are available on the Keltbray Business Management System. New employees are briefed on the use of the Business Management System and locations of the Keltbray policies and any reviews or key changes in the policies are advised to employees.
This policy is governed by and supports our Keltbray Code of Practice and recognises the facility afforded by the Whistleblowing policy statement (GRP-CAL-PCY-029).
*Refer to GRP-CAL-FRT-004 for the full list of subsidiary companies.
Group Chief Operating Officer
Date: July 2022