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 there is no slavery or human trafficking in our business or our supply chain.

Organisational structure

Byrne Group Ltd. is a 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. Byrne Group’s subsidiaries are Byrne Bros. (Formwork) Ltd and F.B. Ellmer Ltd.

We are committed to being a responsible business, with integrity and respect two of our core values, and we expect our supply chain to uphold the same ethical standards.

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.

Relevant policies/documents

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

• Whistleblowing Policy
• Anti-bribery and Corruption Policy
• Byrne Group Corporate Social Responsibility Policy
• Byrne Group Responsible Sourcing Policy
• Byrne Group Sustainability Policy
• Company Employee Handbook
• Subcontractor/supplier agreements
• Eligibility to Work in the UK Procedure
• IS0 9001 Quality Management Systems
• Modern Slavery Act labour supply risk assessment
• Modern Slavery Act supplier risk assessment

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 set the following KPI:

• All new starters with the company to receive Modern Slavery Act training on joining the business.

During the reporting period, all new starters received training either through our bespoke online training module or through our site induction process, which includes slides on the Modern Slavery Act. We will continue with this KPI.

Control measures

Our HR Manager ran supply chain Labour Practices’ workshops to ensure they are aware of legislative and Byrne Group requirements in relation to the Modern Slavery Act, as well as subjects such as equality, diversion and inclusion, eligibility to work in the UK, recruitment, worker contracts and pay.

We reviewed our Anti-slavery & human trafficking policy statement and policy to ascertain if our, or our supply chain’s, risk profile had changed.

• We will continue to work collaboratively with our supply chain to endeavour to ensure they meet their legal obligations under the Act.

We undertook a review of all our policy statements, which include:

• Anti-bribery and Corruption Policy
• Byrne Group Corporate Social Responsibility Policy
• Byrne Group Responsible Sourcing Policy
• Byrne Group Sustainability Policy

We continued to assess employees’ eligibility to work in the UK, in accordance with the Immigration, Asylum and Nationality Act 2006, as fraudulent documents can be an indication of modern slavery. The steps taken 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.

We completed an internal audit on our workforce, looking specifically at three markers to see if individuals had the same details:

• Permanent Address
• National Insurance Number
• Bank Account

No issues were raised during this audit. We will undertake another audit in the year ahead.

Two of our external certification bodies included the Modern Slavery Act in their assessment criteria during audits – no issues were raised.

Sean Byrne
Byrne Group Compliance Director

First issued October 2016

Reviewed October 2020