Modern Slavery Statement

Modern Slavery is a crime which occurs in many forms and for the purpose of this policy includes any act of slavery, servitude, bonded, forced or compulsory labour, child labour or human trafficking. All of these acts are normally conducted for the purposes of either personal or commercial gain and without exception result in the abuse and exploitation of an individual’s human rights.  

Seymour Civil Engineering is fully committed to the prevention of Modern Slavery and Human Trafficking and will not tolerate or condone any such identified act within any aspect of our business activities. 

This statement is made pursuant to section 54 of the Modern Slavery Act 2015, it sets out the activities undertaken by the Company in respect of the prevention of Modern Slavery and Human Trafficking and constitutes the Company’s annual Modern Slavery statement for the financial period 1st October 2022 to 30th September 2023. 

Organisation structure 

Seymour provides a diverse range of specialist engineering services in support of the creation and maintenance of infrastructure assets for both public and private sector customers. 

Our work is conducted solely in the United Kingdom (Northeast and Yorkshire) and delivered by a directly employed workforce, supplemented where necessary by temporary workers supplied by reputable recruitment partners, all of whom are fully eligible to work within the United Kingdom. 

Seymour recruits either directly or via a limited number of reputable recruitment partners, who are vetted prior to becoming a recruitment partner.  

Seymour believes that no worker should pay for a job.  The cost of the recruitment of ANY worker engaged by Seymour Civil Engineering will be borne by Seymour Civil Engineering not the worker and, as part of our due diligence and risk identification processes, we will ensure that our supply chain and recruitment partners also adhere to this principle. 

Supply chain 

Given the nature of our organisational structure, our model of directly employed work delivery, and our use of a UK-based supply chain, we consider that any exposure to the risk of Modern Slavery or Human Trafficking is extremely low and that should any risk exist it is most likely to be within the extended supply chain.  

We work closely with the Tier 1 providers of our supply chain in the identification of such risks to ensure they are addressed in an appropriate manner. 

Modern Slavery Policy 

Seymour Civil Engineering has implemented a comprehensive policy in respect of Modern Slavery and Human Trafficking.  

This policy and supporting procedures detail our business approach to the prevention of Modern Slavery and Human Trafficking, along with the processes used to support and deliver our commitment.  This policy and commitment have been communicated to our colleagues and supply chain partners for their information and action. 

We operate a risk-based approach to the identification of Modern Slavery and Human Trafficking, the principle of which is based on the location of the product or service, industry sector, supplier relationships, and existing data held, supported by additional information and guidance obtained from, but not limited to, sources such as the Global Slavery Index, Corruption Perceptions Index and US Department of Labour Lists of Goods and Suppliers. 

Due Diligence and Identification of Risk 

Seymour Civil Engineering ’s policy of direct employment is supported by robust processes which ensure that an individual’s identity is confirmed, and they have a legitimate right to work in the United Kingdom.  This policy and the right-to-work checks undertaken by our staff significantly reduce the risk of directly employing forced labour or those who may be subject to human trafficking. 

Where Seymour Civil Engineering does utilise labour only sub-contractors, we have introduced due diligence checks to ensure that, as a minimum, labour providers comply with our commitment to the Prevention of Modern Slavery and their processes for recruitment contain no illegal labour practices. 

Notwithstanding that Seymour Civil Engineering ’s Supply Chain is primarily UK based, we have instigated a risk assessment of supply chain activities to identify and prioritise any areas which may pose a risk of Modern Slavery. 

Key Performance Indicators 

Our commitment to and activities supporting the prevention of modern slavery remain a key priority for Seymour Civil Engineering.  

We have a confidential independent whistleblowing hotline and employees, and suppliers, are encouraged to raise concerns about anything which may not be in line with our ethics. 

In 2022/2023: 

• No incidents of Modern Slavery were reported. 
• We released a mandatory eLearning module on Modern Slavery for all relevant staff to complete. 
• Right to Work in the UK checks were completed for all workers prior to employment. 

Our plan for 2023/2024 includes: 

• Refresher training of mandatory eLearning module, with a target of 100% completion (including new joiners) This is monitored by the HR Department. 
• Continuing to promote internal and external reporting frameworks. 
• Undertake an annual review of our Ethical Trading Policy and Sustainable Procurement Policy. 
• Continue to review our procurement and supply chain and their processes, to understand the activities they undertake, and to ensure that Modern Slavery and Human Trafficking is not taking place within our supply chain. 
• Undertake a defined programme of audits in relation to identified key high-risk suppliers. 
• Engaging with our key strategic suppliers and industry bodies to engage with their supply chains to discuss and understand capability, best practice, and learning on Modern Slavery to continuously improve our approach to Modern Slavery. 

Communication and Training 

Our commitment to the prevention of Modern Slavery and Human Trafficking emanates directly from our Directors.  Their leadership and commitment to this important social issue and legal obligation has been clearly communicated both internally to colleagues and externally to subcontractors and Tier 1 supply chain partners. 

All colleagues receive training in relation to Modern Slavery appropriate to their position and their involvement/responsibility in the engagement of workers and/or for dealing with supply chain matters. 

Commitment 

The Board of Directors have reviewed, accept and fully support this statement and formally approved it on 1st December 2023. 

We will utilise our annual statements to publicly reaffirm our continued commitment and to communicate this evolution, including the steps we have taken and will continue to take, to deal with this morally and socially important issue. 

Adam Harker

Managing Director 

Date: 1st December 2023