URBAN&CIVIC PLC

Policies described

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

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation

Grievance mechanisms

Through trade unions or other worker representative groups

Other monitoring

Our Employee Advisory Group provides a channel for employee reps to share feedback on working conditions with management so these can be discussed and considered in decision-making.

Demonstrated progress

Our Statement includes a ‘Further Steps’ section to guide future efforts in tackling modern slavery and support continuous improvement. We are committed to an annual review of the Statement, providing a structured process for monitoring progress. The review incorporates input from senior leaders who are well placed to drive change within the business. These further steps are designed to deliver positive outcomes across several areas and with shared accountability for their implementation.

Reported risks and mitigations

• Risk: Contractor/sub-Contractor use of low-skilled temporary workers on our sites - supply chain labour exploitation
• Area: Within your supply chains
• Tier: Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants Refugees
• Location: United Kingdom
• Mitigation: We have comprehensive due diligence requirements as part of our tendering and contract processes and have an Ethical Labour Policy for our supply chain confirming expectations. We operate a relatively small list of preferred contractors allowing for deeper understanding of their practices and to allow increased influence and reinforcement down their supply chains. Annual monitoring processes in place for ongoing compliance.
• Risk: Lack of visibility around subcontracting arrangements
• Mitigation: Tendering and contractual documentation process requires contractors to trace their supply chain for all direct and subcontracted labour as well as provide training for employees and their supply chain - there is an effective flow down of labour standards and modern slavery obligations. Annual compliance process is in place. Further steps as identified in our Statement will only improve risk mitigation further.
• Risk: Lack of awareness and reporting
• Mitigation: Our Ethical Labour Policy for our Supply Chain is very clear on required compliance by our third parties including having effective controls to identify modern slavery in their own supply chains. One such example is the provision of appropriate training on modern slavery and ethical labour.