S.WALSH & SON LIMITED

Policies described

Freedom of movement Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Human resources Executive-level staff

Worker engagement and working conditions

Your suppliers Workers within your organisation Law enforcement, such as police, GLAA and other local labour market inspectorates

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

Right to Work checks for all new starters; manager-led personnel checks; whistleblowing channel open to employees, customers and suppliers.

Demonstrated progress

GRS fosters a risk-averse attitude across all business areas and implements KPIs to promote and measure the advancement of efforts company-wide. This includes achieving 100% compliance with Right to Work and enhancing awareness of company policies, notably by integrating this into the new employee induction programme. For our next statement, GRS aims to complete the roll-out of its modern slavery awareness training across the workforce and report on completion rates.

Reported risks and mitigations

• Risk: Long and complex supply chains, including widespread use of subcontracted labour, therefore a high turnover of temporary construction workers, in the UK
• Area: Industry Wide
• Group: Migrants
• Location: United Kingdom
• Mitigation: GRS is committed to partnering with suppliers that adhere to the standards set forth by the Ethical Trading Initiative and the International Labour Organisation. Furthermore, at GRS, we educate our employees about the principal indicators of unethical trade practices and offer a whistleblowing helpline for all employees. Prior to the engagement of any supplier, we carry out a vetting process to ensure they meet compliance standards and continue to monitor them regularly.
• Risk: Industry reliance on migrant workers, resulting in potential language barriers between employers and workers in the UK.
• Mitigation: GRS is committed to partnering with suppliers that adhere to International Labour Organisation standards and applicable UK labour law. GRS fosters a risk-averse attitude across all business areas and implements KPIs to promote and measure the advancement of efforts company-wide. This includes achieving 100% compliance with Right to Work and enhancing awareness of company policies.
• Risk: Subcontractors in the UK construction supply chain may self-regulate labour standards, risking exploitation of low-paid site workers.
• Mitigation: GRS holds those we contract with to appropriate standards. Where a party fails to comply with our expectations or legal requirements, we take remedial action, report concerns as appropriate, and may terminate the trading agreement.