Modern Slavery Policy

Integra Buildings is committed to building an organisation free from Modern Slavery. This Modern Slavery Policy and Procedure applies to all employees (and workers, as applicable).

Under the Modern Slavery Act 2015 modern slavery is a criminal offence. We are committed to ensuring that modern slavery is not taking place anywhere within our own business or in any of our supply chains.

1. Key Principles

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all employees, suppliers, or business partners over which we exercise control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. All employees must read, understand and comply with this policy.

Integra Buildings expects all suppliers, contractors and business partners to observe the same high standards and we will include in our contract’s specific prohibitions against the use of forced, compulsory or trafficked labour, or any held in slavery or servitude. We will communicate our approach to all suppliers, contractors and business partners at the outset of our business relationship.

2. Employment

Our recruitment process for our employees, prohibits modern slavery or the recruitment of individuals that are under 16 years of age. Our recruitment processes are designed to ensure that all prospective employees are legally entitled to work in the UK and safeguard employees from any abuse or coercion.

Integra buildings are fully compliant with all applicable legislation regarding the recruitment and protection of employees within the workplace, compensation for work undertaken including Health and Safety legislation and minimum wage.

Integra Buildings does not consider there is a risk of modern slavery being present in its directly employed workforce, however we regularly review our policies and practices.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Managers must identify where additional training on modern slavery is required, for example where an employee is responsible for managing partnerships.

3. Reporting

Integra Buildings encourages open communications and will provide support for any individuals, who have reasonable suspicion or any evidence of non-compliance with the Modern Slavery Act in connection with any of Integra buildings supply chain or sub-contractors in good faith under this policy.

If they turn out to be mistaken, Integra buildings are committed to ensuring no individual suffers any detrimental treatment as a result of reporting in good faith, that their suspicion that modern slavery of whatever form is or may be taking place, in any part of our own organisation or in any of our supply chains. Employees who believe they have suffered any detrimental treatment should inform their line manager.

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary following needs analysis. Integra Buildings external supply chain, if requested, training will be provided by our Procurement team.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. Any employee who believes or suspects a breach of this policy or the Modern Slavery Act 2015 has occurred or that it may occur must notify their line manager, the purchasing manager as soon as possible. Alternatively, concerns can be raised using Integra Buildings Whistleblowing Policy and Procedure.

Employees who are unsure about whether a particular act, the treatment of workers more generally, or working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery can raise it with their line manager.

Any employee who breaches this policy or the Modern Slavery Act 2015, subject to investigation, may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Any breaches of the Modern Slavery Act 2015 suspected or proven will also be reported to the relevant organisations for criminal investigation.

4. Procurement

The purchasing manager is nominated to ensure that Integra Buildings external supply chain remains compliant in line with this policy. Through self-assessment, key suppliers are required to confirm agreement and compliance with this policy.

The purchasing manager at his or her discretion, will implement appropriate audits of any key supplier on identification of potential risk. All staff that are involved in procurement activity are aware of and follow modern slavery procurement government guidance.

Integra Buildings may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy or fail to allow the purchasing manager appropriate audit/assessment access.

This policy will be communicated to all current members of staff, included in the new employees induction procedures. This Policy has the full support of the senior management and the board of Directors.

This policy will be reviewed on an annual basis or sooner if appropriate with any changes brought to the attention of all concerned.

Chris Turner

Commercial Director

January 2021