Modern Slavery and Human Trafficking Statement

Introduction

This statement is made in accordance with Section 54, Part 6, of the Modern Slavery Act 2015 and sets out Byrne Group's actions to understand all potential modern slavery risks related to our business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business or our supply chain.

Organisational structure

Byrne Group is a family owned business operating in the construction industry that offers a complete, integrated construction service. We specialise in concrete frame construction, high quality new-build, fit-out and refurbishment across London and the South East of England. Byrne Group’s subsidiaries are: Byrne Bros., Chorus and Ellmer.

Responsibility

Policy: The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Byrne Group Compliance Director has primary and day to day responsibility for implementing this policy, including monitoring its use and effectiveness, and for its review.

Risk assessments: Human rights and modern slavery risk assessments are undertaken and will be reviewed, as a minimum, on an annual basis.

Relevant policies/documents

The following is a non-exhaustive list of policies/documents that assists with our approach to prevent slavery and human trafficking in our operations:

Whistleblowing Policy

Anti-bribery and Corruption Policy

Company Employee Handbooks

Subcontractor/supplier agreements

Byrne Group Corporate Social Responsibility Policy

Byrne Group Responsible Sourcing Policy

Eligibility to Work in the UK Procedure

IS0 9001 Quality Management Systems

Due diligence 

As part of our supplier on boarding processes we undertake due diligence, and regularly review our existing suppliers. 

Performance indicators

We have reviewed our key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, we have set the following KPI:

• All current staff/site personnel to have completed anti-slavery and human trafficking training by 31st December 2016

Control measures

We have produced an anti-slavery and human trafficking policy, which is published within company employee handbooks, to complement our existing policies regarding the human rights of workers.

We are reviewing the vetting process for our supply chain, and are working collaboratively with them, to endeavour to ensure they meet their legal obligations under the Act.

To make staff and site personnel aware of the principles of the Modern Slavery Act 2015, including risks and reporting procedures, we have produced training modules and posters that will be rolled out by 31st December 2016.

As part of our drive for continual improvement, we have implemented best practice controls for assessing employees’ eligibility to work in the UK. These are detailed in our Eligibility to Work in the UK Procedure. We expect our supply chain to adhere to our expectations with respect to their own workforce

Sean Byrne
Byrne Group Compliance Director
October 2016