This document sets out the Modern Slavery and Human Trafficking Statement of HMH Civils Limited and its subsidiary operating companies, collectively known as ‘HMH’. It covers activities undertaken by the Group throughout all its office locations and operations UK wide.
This document will be reviewed for continued suitability, will be communicated within the HMH Group and, if appropriate, made available to interested parties. The review interval for this document is minimum 1 year.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. HMH takes a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships.
Responsibility for our anti-slavery and human trafficking initiatives is as follows:
Policy: The Group Board is responsible for implementing and reviewing this policy statement. It is supported by the Boards of the Companies within the Group and our Group Operations team, which includes those responsible for our HR, Finance, Health and Safety and Integrated Management System functions.
Investigations: The Group Board, supported by the Group Operations team, is responsible for investigations in relation to any known or suspected instances of slavery and human trafficking in order to identify, prevent and mitigate any incidences of modern slavery in our operations and supply chains.
We understand that the Private Sector has an important role to play in helping to end slavery, and we understand the importance of applying the requirements of the Modern Slavery Act 2015 in the UK and following the UN Guiding Principles on Business and Human Rights across all our operations worldwide.
Members of the Group Board and subsidiary Company Boards are trained in how to identify, report and deal with a breach of this policy. The policy is explained to staff by means of cascade briefings and as part of staff induction.
Our Board members and senior staff demonstrate leadership in their commitment to ensure slavery does not take place in HMH by ensuring our policies and employment processes are followed, and that our Human Resources, Health and Safety and Procurement functions are adequately trained and resourced.
We check the eligibility of employees and sub-contractors to work in the countries where they are based.
We require prospective and existing service providers to confirm that modern slavery and human trafficking practices do not take place in their organisations.
It is fundamental to our business ethos, core values and operating principles to identify, prevent and mitigate incidences of modern slavery in our operations.
Health, safety and wellbeing is a standard agenda item on all external project meetings and for internal HMH meetings attended by more than three members of staff.
Reporting and review of health and safety procedures is included on the agenda of all Directors’ meetings.
HMH Group consists of the following operating companies:
| Operating company Registration | location |
|---|---|
| HMH Civilis Ltd (trading as HMH Consulting) | England |
| subsidiary: Northern Bespoke Developments Ltd (NBD) | England |
| subsidiary: NBD Groundworks | England |
| subsidiary: CL Transport | England |
In the financial year ending 31 December 2020, we directly employed 55 staff in the UK. Our supply chain included organisations and individuals who acted as sub-consultants or sub-contractors to assist in the delivery of our professional services, and we purchased office services and equipment from external suppliers.
HMH provides professional Civil Engineering services through our offices in the UK.
Our principal area of operations is a construction company covering the Northeast, Yorkshire and Humber areas. With only the best quality and time efficiency in mind our expertise covers many forms of civil engineering, groundworks, customer care and external works. We provide our services to a considerable amount of well-known new build and construction companies.
We consider that our operations have a very low risk of involvement with modern slavery or human trafficking practices because:
• We use directly employed staff for the majority of our technical work and we have strong policies and procedures in place to ensure their well-being, fair treatment, and a leading remuneration and welfare package;
• Our staff are typically highly academically qualified and therefore likely to have a choice of jobs and be free to move between job opportunities;
• We purchase goods and services from suppliers with strong ethical and welfare policies and outcomes who are able to confirm that modern slavery and human trafficking practices do not take place in their organisation.
We have a culture of openness in HMH and encourage the reporting of any concerns or breaches of our policies, anonymously if preferred.
We check the eligibility of employees and sub-contractors to work in the countries where they are based. Before employing new staff, we take practical and proportionate steps to reduce risks by carrying out appropriate verification checks. All permanent employees must provide evidence to demonstrate they have the right to work in the country of their employment.
Our Supplier Assessment Processes require prospective and existing service providers to confirm that modern slavery and human trafficking practices do not take place in their organisations. We expect our suppliers to review their own supply chains for compliance with our high standards. We do not rely solely on self-assessment in our supply chain and undertake our own checks and audits. We follow up any reported concerns and may terminate the relationship if a supplier failed to comply with this policy or agree to an audit.
We pay all our permanent staff above the legal minimum wage and the Living Wage, or its equivalent, in the countries in which we operate. We require our suppliers to pay at least the legal minimum wage in the countries where they operate.
We maintain a suite of policies that combine to ensure all HMH business is conducted in an ethical manner and demonstrate our commitment to being a transparent organisation. All staff are required to read and confirm they have understood the policy content. In particular, our Whistleblowing Policy protects anyone who highlights to us any risk of modern slavery or human trafficking within our business or supply chain.
Our Employee Assistance Programme provides our staff with a secure way of seeking advice about any modern slavery or human trafficking issues personally affecting them or their families.
Notification of a breach or potential breach of this policy is escalated to the Chair of the Group Board. The Chair will convene a ‘task and finish’ group, including our Director of Group Operations and Head of Business Management, to investigate and report on actions required.
We are committed to ensuring there is no modern slavery or human trafficking in any part of our business and, in so far as is possible, to requiring our suppliers hold a similar ethos. We intend to increase the quantity and scope of our supplier audits.
To support this commitment, we will review and update our existing business policies and will share these with our supply chain, as appropriate.