Company risk assessment

The majority of revenue earned by our business is through specialised service provision carried out by full-time employees of Group. In providing these services, we maintain ongoing relationships with over 750 suppliers. We believe our highest areas of potential risk are within our supply chain and in the use of agency labour. In order to mitigate our supply chain risk and as part of their contractual relationship with us, we require suppliers in the UK to confirm that they will comply with our Supplier Code of Conduct and always pass through our approved contractor requirements.

We mandate the highest employment standards in all our operations, as outlined in the Code of Conduct. As part of our ongoing due diligence, all our suppliers are robustly checked during the onboarding process and before being commissioned for any work. We check whether they have a modern slavery policy and whistleblowing systems in place, irrespective of turnover.

The Group’s Head of Compliance / Risk Committee have concluded that whilst the risk of modern slavery occurring in our immediate lines of business is low, there is always a risk of modern slavery occurring in areas of our operation where we have less visibility over second-tier suppliers or where suppliers are dependent on agency labour. In order to address this risk, the Group has made it a formal requirement for all suppliers to declare the use of any subcontractors employed in the delivery of services to us and we will not accept the use of subcontractors beneath the second tier of supply.

Our policies in relation to modern slavery

The Group is committed to acting in accordance with the law. Our companies and employees operate under a number of policies designed to ensure a high standard of social governance and ethical compliance, of which the cornerstone is the Supplier Code of Conduct. All policies are available internally on the Group’s intranet and key policies are placed on our website.

Supplier Code of Conduct

Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships. It is a fundamental commitment to comply with all applicable legal requirements and with high ethical standards. The code outlines responsibilities to colleagues, customers and to the Group. The Supplier Code of Conduct highlights these commitments and sets out how we will work with our suppliers to address potential areas of risk. If a problem is identified we will work together with the supplier to address any areas of concern. Where we are unable to satisfactorily resolve the issue we may terminate our use of them as a supplier/contractor.

Policies

In addition to the Supplier Code of Conduct, the Group maintains policies on customers and suppliers, human rights and the rights of employees. Specific policies applicable to modern slavery include:

• Modern slavery and human trafficking policy
• Recruitment and vetting procedure
• Whistleblowing policy and procedure
• Working time regulations policy
• Bullying and harassment policy
• Bribery policy

Our suppliers

Of the more than 750 suppliers we currently procure products and services from, 361 are preferred first tier suppliers whom we consider to be material to our business and who may, in-turn, have direct workers and sub-contractors employed on both a permanent and temporary basis. In order to assess the level of risk to which we might be exposed, in 2022 we conducted a desk-based risk assessment of the 361 preferred suppliers across key sectors such as:

• Building, Construction and Related Trades
• Consultancy
• Electrical and Plumbing
• Energy & Fuel
• Equipment and Tools
• Facilities Management
• Financial
• Health Services
• HR and Recruitment
• Logistics and Security
• IT Software & Hardware
• Maintenance & Operations

For the purpose of prioritising action with the Group suppliers, we have graded how effective suppliers’ systems are for managing the risk of modern slavery and trafficking.
Our risk assessment has calculated a risk rating for these suppliers taking into account sector risk, individual company risk and management system risk.

Our findings suggest that, across all sectors, the greatest risk lies with smaller companies which in some cases lack formal policies and processes on ethical trade, labour and human rights or lack management systems and monitoring programmes to effectively deal with modern slavery.

Going forward, in 2023 we will be conducting 10 detailed, on-site risk assessments of suppliers who operate in the riskiest sectors and/or with whom we have the highest spend. The key aims of these assessments are to map out management practices and identify key areas of intervention. We will use these findings to strengthen our due diligence processes and monitor our performance. These risk assessments, combined with the previous desk research, will give us a robust baseline for compliance, enhancing systems and future action in managing the issue across our operations.

Key Performance Indicators (KPIs)

We have worked with external modern slavery experts to review our existing systems, benchmark our level of compliance and advise on enhanced systems, due diligence and management KPIs. Since 2019, the Group has used the following KPIs to measure our effectiveness:

• The number of incidences of modern slavery reported within the Group’s own operations.
• The percentage of relevant Group employees trained on preventing modern slavery and trafficking.
• The percentage of suppliers aware of the Modern Slavery Act and its requirements.
• The percentage of suppliers who have a modern slavery policy.
• The number of incidences of modern slavery reported in our supply chain.
• The percentage of suppliers subjected to a modern slavery risk assessment/audit.

Appropriate targets for the KPI’s are reviewed and agreed annually.

Enhancing supplier adherence

To ensure all those in our supply chain comply with our values, over the next year we will be
putting into place additional measures to ensure compliance with our Modern Slavery programme. This will include monitoring of suppliers’ performance on labour and human rights, ensuring traceability in supply chains, a review of agreements and dealings with suppliers to ensure compliance with anti-slavery measures and working with our suppliers when modern slavery risks are identified.

Previous work done

Since 2018, the Group has been working with labour and human rights experts to carry out research into the modern slavery risks across its supply chains to enable it to develop its due diligence processes. This has been mainly desk-based research looking at the risks of modern slavery in key sectors and gathering intelligence through direct interviews with suppliers across the UK. In order to obtain a clearer picture of how these risks were being managed in 2018, a total of 11 Modern Slavery Risk Assessments and direct interviews took place with suppliers to check management practices, policies and procedures. This helped the GFM group to identify improvements in its due diligence during supplier tendering and onboarding processes. There are now clauses covering modern slavery in the Group’s standard conditions of purchase.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, in 2018 the Group delivered modern slavery training to over 80 directors, managers and company employees. Further direct training was provided to our Board of Directors in 2019 covering:

Modern slavery in construction and facilities management in the UK, who is at risk and how. Hotspot and high risk areas identified in supply chains risk assessments and recommendations on how to manage these risks.
Key questions to help procurement and technical teams identify potential issues with suppliers against provisions of the Modern Slavery Act.
The need for increased diligence and scrutiny to mitigate the increased risk of forced labour due to potential labour shortages arising from Brexit in local labour markets.

In 2023, we will be extending training to our staff, suppliers and service providers through an online training tool. This will form an integral part of the induction process for staff and a requirement for all new suppliers to receive online modern slavery training during their onboarding process.

Whistleblowing policy

Since 2020, the Group has operated a global ”Speak Up” or whistleblowing policy for all its employees and those working on Group sites. This is supported with a procedure to assist employees and suppliers when ’speaking up’ on a confidential basis. The policy is designed to allow both employees and suppliers to raise concerns to the internal audit team and to disclose information which the individual believes highlights or would indicate illegality, unethical behaviour or other serious malpractice, including any instances or suspicions of modern slavery. This also includes reporting actions or practices by our suppliers which may be inconsistent with the Supplier Code of Conduct or Modern Slavery Policy.

Continuous improvement

The Group takes compliance with the Modern Slavery Act seriously and believes in a continuous improvement approach. At least once every year we will review our existing anti-slavery and human trafficking systems to ensure that they reflect current best practice and update them as required.

Mapping of our supply chains

The products used in the performance of our services are an essential but relatively minor component of our operations, making up between 5% and 15% of the service cost, depending on the business category. Throughout 2023 and 2024 we will be working with our suppliers to map out our product supply chains as part of our due diligence in procurement.

Further steps

We recognise the extremely complex nature of modern slavery and we will continue to monitor our operational practices. We have identified the following as key actions for 2023:

• Further investigation into suppliers of services in the high-risk indirect procurement categories such as cleaning, facilities management and construction to ensure compliance;
• Development of online training for suppliers and new employees;
• On-site modern slavery risk assessments of our top 10 suppliers across key sectors, based on spend.
• Refresher training for the procurement team; and
• Quarterly review and discussion with procurement managers and compliance teams.

This statement applies to all operations associated with Grosvenor Facilities Management Limited. It is approved by the Board of Directors of the Group, and signed on their behalf.