The Modern Slavery Act 2015 requires companies who transact business in the United Kingdom to disclose their efforts to eradicate slavery, forced labour and human trafficking from their supply chains and their own business.
EMCOR UK offers a comprehensive range of hard and soft facilities management services to our customers in the UK. These include mechanical and electrical maintenance, project management, estates maintenance, manned guarding, cleaning, catering and waste management services. The Company requires the highest standard of business conduct in its relationships with customers, supply chain partners and employees and strives to conduct its business in accordance with the highest standards of business ethics. It is committed to operating its business in a manner that ensures the absence of slavery and human trafficking in its operations and supply chain.
EMCOR UK requires all employees to comply with its Code of Business Conduct and Ethics, which sets out the behaviours we expect from employees in their dealings with colleagues, customers, supply chain partners and others. All employees are expected to act with integrity and follow these standards of behaviour.
EMCOR UK is an equal opportunities employer and our recruitment and employment policies require compliance with UK employment legislation, which ensures employee rights are safeguarded. We have a Whistleblowing Policy in place that aims to encourage employees to report any suspected wrongdoing in the knowledge that their concerns will be taken seriously and investigated as appropriate and their confidentiality respected.
EMCOR UK requires all our supply chain partners to conduct business in a lawful and ethical manner and to comply with our Sustainable Supply Chain Charter. All supply chain partners sign up to this charter as part of our supplier on-boarding process and in accepting our trading terms and conditions.
The Executive Leadership Team takes responsibility for implementing these policies and provides adequate resources to monitor our risk and control measures, which aim to ensure that slavery and human trafficking is not taking place within the company or within our supply chains.
EMCOR UK has undertaken a risk assessment in respect of the likelihood of slavery and human trafficking taking place in its business and considers the risk to be minimal. EMCOR UK’s business activity is undertaken within the UK and the nature of the professional and technical services provided to our customers limits the potential risk of slavery and human trafficking within the business and our supply chain. Furthermore, any risk of slavery and human trafficking within our organisation is mitigated as a result of clear business policies and procedures.
EMCOR UK regularly notifies its employees of their obligation to comply with our Code of Business Conduct and Ethics and employees are reminded of the importance of ethics and legal compliance. All senior managers within the business undertake annual training programmes on ethics and business conduct. We believe that these, along with our communication programmes and employee training, help create an ethical and legally compliant culture.
EMCOR UK utilises agency labour, which represent about 5% of our total headcount. We have trading agreements in place with all agency labour providers that require them to comply with all UK employment legislation and regulations, including the Modern Slavery Act 2015.
EMCOR UK builds long standing relationships with our supply chain partners and makes clear our expectations of business behaviour. We have a zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values and to demonstrate the highest standard of business conduct, which includes adopting our Sustainable Supply Chain Charter. We audit our supply chain partners to ensure compliance with our policies and procedures and to confirm that they are operating with high ethical business standards.
During 2020, we held a modern slavery workshop with our main supply chain partners and all our preferred supply chain partners were asked to complete a modern slavery questionnaire. We have completed an initial review of the responses to this questionnaire and, during 2021, our target is to undertake a detailed assessment of at least 50% of these responses and agree an action plan to remedy any concerns arising. Additionally, we will be arranging further associated training and workshops.
As a partner in the Supply Chain Sustainability School, we also work with the School and other partners in developing a consistent approach to the Modern Slavery Act across the facilities management industry.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year ended 31 December 2020. This statement was approved by the executive management on 29 April 2021.
EMCOR Group (UK) plc
29 April 2021