Policies

Modern Slavery and Human Trafficking Statement 2022

Introduction

This statement is made pursuant to S.54 of the Modern Slavery Act 2015 (“the MSA”) and sets out the steps taken by SCAPE Group Limited (“SCAPE”) and its subsidiary companies[1] to prevent modern slavery and human trafficking in its (and their) business and supply chains for the financial year ending 31^st March 2022.

SCAPE’s policy is to conduct its business in an honest, open and ethical manner and to act professionally, fairly and with the utmost integrity in all our business dealings. Accordingly, SCAPE aims to ensure that its supply chains and every part of its business are, and remain, free from slavery and human trafficking.

During this reporting period SCAPE has commenced a modern slavery programme which includes a review of its policies and procedures relating to the risk of modern slavery across its own business and operations, along with resetting its engagement with its framework partners as part of the tender and awards process.

Further to the appointment of partners to deliver next generation construction frameworks for England, Wales and Northern Ireland, and for Scotland, SCAPE formed a Modern Slavery and Ethical Labour Working Group. This group brought together those partners, and other key stakeholders, to ensure modern slavery risks were considered during the lifecycle of respective construction projects.

In October 2021 SCAPE and its partners announced the commitment to the following actions:

Target use of appropriate Social Enterprises : Utilise ‘Supply Change’ and the Social Partnership Portal to identify and engage with Social Enterprises who support the survivors of Modern Slavery and target their use on SCAPE / all Projects to create increased opportunities for survivors.

Workforce Engagement Surveys & Labour Practice Audits : Align Workforce Engagement Surveys and Labour Practice Audits across Partner preferred providers to identify the outcome requirements across our providers to ensure consistency in our surveys and audits. This will aid feedback of issues & trends to the Working Group.

Workforce Engagement Surveys & Labour Practice Audits : Undertake Workforce Engagement Surveys & Labour Practice Audits on all Major Projects, (to be determined by Partner), focused on high-risk packages, and share key learning, key risks and trends with the Working Group.

Project / Site Inductions : Partners will share with the Working Group the content of their current Project / Site Inductions in respect of Modern Slavery / Ethical Labour with the aim of co-ordinating and agreeing a consistent / best practice approach to addressing Modern Slavery / Ethical Labour in Project / Site Inductions.

Tool Box Talks : Partners will share with the Working Group the content of their current ‘Tool Box Talk’ in respect of Modern Slavery / Ethical Labour’ with the aim of co-ordinating and agreeing a consistent / best practice approach to address Modern Slavery / Ethical Labour in these TBT’s.

Modern Slavery Whistleblowing & Helpline : Partners will ensure that every Project site has a 24/7 independent Modern Slavery Helpline available to the general workforce, including whistleblowers and victims, to report any incidence or suspicions of modern slavery, together with a clearly identified, independent escalation process in place.

Collaboration with Industry & Academia : Work with appropriate industry bodies and Academia (e.g. Nottingham University Rights Lab) to collaborate and share appropriate / agreed data to support further research in this area utilising outputs from the above.

This activity will continue into 2022/23, forming part of the modern slavery programme referred to above.

This statement has been approved by the Board of Directors of Scape and signed by Mark Robinson, Group Chief Executive.

[1] Scape’s wholly owned trading subsidiaries on behalf of whom this statement is also given include Scape Procure Limited (Company No. 09955814), Scape Procure Scotland Limited (Company No. SC584373), Scape Venture Limited (Company No. 07710482) Lungfish Architects Limited (Company No.09828111) and Construction Waste Portal Limited (Company No. 13768718).

Structure, business and supply chains

SCAPE was established in 2005 as a Private Limited Company under S95 of the Local Government Act 2003 as Scape System Build Limited and changed its name to SCAPE Group Limited in April 2016.

SCAPE is jointly owned by its six member authorities: Derby City Council, Derbyshire County Council, Nottingham City Council, Nottinghamshire County Council, Warwickshire County Council and Gateshead Borough Council.

SCAPE offers a suite of performance- managed construction services frameworks, property services, innovative design solutions, community investment opportunities and joint ventures that are available to any public body in the United Kingdom. As a public-sector organisation, SCAPE fully appreciate the role that the built environment plays in the context of service delivery and the local economy.

The single-supplier frameworks offer public sector customers access to a range of construction and construction-related services, property services and design solutions delivered by contractors who have been selected through an OJEU-compliant competitive tender process. These services are made available via access to the frameworks below:

National Construction Frameworks

Civil Infrastructure & Engineering Frameworks

Regional Construction Frameworks

Professional Consultancy Services Frameworks

Policies relevant to slavery and human trafficking

SCAPE operates a number of internal policies with a view to ensuring that it is conducting business in an ethical and transparent manner:

• Corporate Social Responsibility Statement: Through this statement, SCAPE acknowledges that its operations will impact upon the economy, society and its employees and is committed to ensuring those effects maximise the positive impacts and minimise the negatives so that the business is run responsibly and in a sustainable manner.
• Code of Conduct: The Code of Conduct makes clear the expectation placed on SCAPE employees to maintain the highest standards of conduct and behaviour when representing the organisation; the Code also covering policies relating to the avoidance of conflicts of interest, impartiality, hospitality, political neutrality and whistleblowing.
• Statement of Ethics: This clearly demonstrates SCAPE’s pride in its reputation for acting fairly and ethically in doing business and the values, commitment and integrity of its employees; the statement also covers the policy relating to anti-bribery and corruption.
• Anti-Slavery and Human Trafficking Policy: This policy specifically prohibits activities linked to slavery, servitude, forced labour and human trafficking and sets out exactly what is expected of Scape’s staff and supply chain in order to prevent it.

Due diligence and steps to assess and manage the risk of slavery and human trafficking in our business and supply chains

In respect of its own operations, SCAPE considered the location of its activities, the roles being performed, the recruitment processes and the absence to date of reports of concerns regarding slavery and human trafficking. SCAPE undertakes “right to work” checks on all its employees prior to them commencing their role. This includes checking, where applicable, that the employee has a valid work visa and is of an appropriate age to work.

Based on these risk assessments, SCAPE deems the risk of human trafficking within its own staff (including agency and contract staff under direct supervision) to be minimal.

SCAPE recognises that the risks within its own supply chain for goods and services need to be assessed. The due diligence process will be reviewed as part of the modern slavery programme and is covered within the objectives for 2022/23.

As for contractor supply chains, SCAPE conducts due diligence on all contractors and suppliers as part of the tendering exercises. This has not identified any issues of concern during the reporting period.

Furthermore, SCAPE’s framework procurements are governed by the Public Contracts Regulations 2015 and SCAPE uses the standard supplier questionnaire, PAS 91, to ensure responsible and compliant procurement. Although the MSA is not covered in PAS 91, SCAPE asks a supplemental question to establish the steps a bidder has taken to ensure that slavery and human trafficking is not taking place in any part of its business or in any supply chain member.

SCAPE’s assessment of a bidder’s response considers the information they provide in respect of compliance and the procedures they have in place to meet the requirements under the MSA.

In each of the signed frameworks, contractual clauses are included to address slavery and human trafficking in the supply chain and cover:

• compliance with the MSA
• sub-contracting
• immediate notification of any actual or suspected breaches of the organisation's policies and any actual or suspected slavery or human trafficking of which it becomes aware or has reason to believe has occurred or might occur
• a warning that failure to comply with these requirements will be deemed to be a substantial failure to comply with the requirements of the framework agreement (substantial failure being capable of occasioning termination).

As a managed framework provider, SCAPE carries out annual audits on all framework contractors. Compliance with the MSA forms part of this annual audit. Evidence is collected for each audit requirement and this is assessed in terms of compliance with legal requirements and/or performance measures. If SCAPE has reason to believe that a contractor or supplier may have been in breach of its requirements and expectations with regard to the use of slave or bonded labour, SCAPE will report this to the GLAA who will take any appropriate action or offer further guidance.

The audits conducted as part of the commitments made by framework partners may be seen as a test of the effectiveness of this approach. The findings of those audits will be evaluated and any changes required considered as appropriate.

Performance indicators

To date SCAPE has adopted a continuous improvement approach to its performance in this area. SCAPE will consider the indicators it can introduce for the coming years during the policies and procedures review and completion of risk assessments.

Key Performance Indicators relating to the activity with framework partners are being developed through the Modern Slavery and Ethical Labour Working Group. The activity during 2022/23 will allow benchmarking to be undertaken for future reporting periods.

Training

The development and introduction of a new Learning Management System delayed the planned training programme. A modern slavery and ethical trading module is included within the system and all employees will be mandated to undertake that module during 2022/23. Training for SCAPE procurement teams may be supplemented by the training available through the wider industry or professional bodies.

Responsibility for compliance

The Managing Director of each subsidiary or associated company is responsible for their company’s compliance with the SCAPE Anti-Slavery and Human Trafficking Policy and the MSA. The Managing Directors are advised and supported by Scape’s Heads of Human Resources, Procurement and Legal & Governance.

Objectives for 2022/23

The modern slavery programme initiated in 2021/22 will continue into 2022/23.

The objectives for 2022/23 are set out below. These incorporate activities across SCAPE and its operations and also its engagement with framework partners.

SCAPE will:

• Undertake a review of its policies and procedures as they relate to modern slavery. To include enhancing existing policies or developing new policies where required.
• Conduct a risk assessment in relation to its own supply chain for goods and services and develop a programme for addressing areas which are considered high risk, to include independent audits where required.
• Ensure that all employees undertake the modern slavery training though the Learning Management System and are made aware of SCAPE’s approach to modern slavery and the policies and procedures which apply.
• Support Framework Partners through the work of the Modern Slavery and Ethical Working Group.
• Provide feedback to Framework Partners in relation to the findings of independent audits conducted to include any emerging threats and trends.

Form and lead a strategic partnership comprising recognised UK leaders on the modern slavery agenda and seek opportunities for further cross industry collaboration.

Approval

This statement was approved by the Board of Directors of SCAPE Group Limited on 2^nd October 2022.

Mark Robinson

Group Chief Executive

SCAPE Group Limited