Modern Slavery Act
Slavery and Human Trafficking Statement 2015/16
16 May 2017
This statement (the Statement) is made on behalf of Bouygues (UK) Limited and all its subsidiaries and affiliated companies in the United Kingdom which include Thomas Vale Construction Limited and BY Development Limited (together, Bouygues) pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act).
Bouygues takes its obligations in relation to the identification, prevention and reporting of modern slavery and human trafficking very seriously and has a zero tolerance approach to the abuse of human rights. Bouygues adheres to a worldwide group Code of Ethics personally supported by Martin Bouygues, Chairman and CEO of Bouygues SA, and pursuant to this undertakes to comply with the strictest legal and moral standards in the conduct of its operations.
The Statement sets out what Bouygues has done in the financial year 2015/2016 to ensure that slavery and human trafficking is not taking place in any part of its businesses or supply chains.
2. Bouygues’ structure, business and supply chain
Bouygues is a provider of development, regeneration and construction services in the United Kingdom to both public and private sector clients. Bouygues is part of a group of companies worldwide which have Bouygues SA, a CAC 40 company listed on the Paris Euronext, as their ultimate parent. Bouygues group has over 120,000 employees worldwide and operates in 100 countries.
As a leading developer and construction contractor, Bouygues has a complex supply chain model that both supports its core businesses and maintains its office and technology infrastructure. Bouygues’ supply chains relate mainly to the following activities:
• Subcontracting – the specialist contractors necessary to deliver certain construction operations on Bouygues construction sites;
• Consultancy – professional and consultancy services from design professionals in various fields, including, without limitation, architecture, engineering (such as structural, civil, façade and mechanical and electrical) lighting, landscape design, sustainability, access consultancy, project management, cost consultancy and surveying;
• Business services – a wide range of products and services necessary to maintain normal day to day operations in its offices and support its core business functions such as cleaning, catering, security, IT support and print services;
• Professional services – professional services such as external training, audit services and advisory services in areas such as tax, regulation, insurance and law.
• Real estate – the purchase or leasing of office space to accommodate staff and operate its business;
• Technology – the systems, software and equipment that are necessary to maintain the technology infrastructure that supports Bouygues’ core business; and
• Travel –mobility is essential and Bouygues works with a number of travel providers such as hotels and airlines.
3. Policies in relation to modern slavery and human trafficking
Bouygues has a number of policies and procedures which are relevant to preventing instances of modern slavery from occurring in its business or its supply chains, including having a dedicated compliance team to whom breaches of any of the following policies can be notified. In particular, the following policies are directly relevant to the subject matter of this Statement:
• Code of Ethics – this requires employees to comply with the principles of the United Nations Universal Declarations of Human Rights, the fundamental conventions of the International Labour Organisation, in particular, concerning forced child labour and the principles of the United Nations Global Compact;
• Health & Safety policy – this policy sets out Bouygues’ commitment and approach to ensuring it provides a healthy, safe working environment for its own staff and contractors that work on-site;
• Harassment & Bullying policy – this policy sets out Bouygues’ approach to preventing the occurrence of discrimination, harassment, bullying or victimisation in the work place;
• Authority limits and contract signing policy – this policy sets out Bouygues’ internal control and governance procedures with regard to approving financial transactions and signing contracts with suppliers. The policy ensure that contracts cannot be entered into without an appropriate level of review and authorisation by a suitably senior and qualified member of staff;
• Whistleblowing policy – this policy encourages employees to bring any bad practice they become aware of to the attention of senior management without fear of repercussions for doing so; and
• Anti-slavery policy – this policy specifically addresses the subject matter of the Act recognising and preventing trafficked, forced, bonded and child labour.
4. Due diligence processes
Bouygues and its suppliers are expected to live up to and adhere to the principles set out in the anti-slavery policy and demonstrate progress towards the standards set out in it.
Bouygues’ procurement practices require that all new suppliers are subject to an appropriate level of screening. The scope of the screening Bouygues performs depends on the nature of the goods or services being procured but can include financial checks, data security assessments, reference checks, obtaining copies of relevant documents and/or site inspections.
5. Risk assessment and management
Section 2 above sets out the areas of Bouygues’ procurement activity where there could be a risk of slavery or human trafficking taking place.
Bouygues assesses and manages the procurement of high value and/or high risk goods and services in accordance with Bouygues’ procurement practices and formal tendering procedures.
Bouygues also employs a team of lawyers and has compliance officers to ensure compliance with its legal and ethical obligations.
Bouygues provides its employees with access to an employee assistance programme (provided by an independent third party company) that can be used by its employees for free and confidential advice in relation to workplace concerns or issues. It also has in place appropriate processes for reporting concerns with the business, including a whistleblowing policy and a designated Compliance Officer. A statement has been made by our Chairman to all staff asking all staff to be vigilant in our workplaces in respect of potential labour exploitation and to report anything giving rise to a suspicion in this area.
As a matter of best practice going forward, Bouygues includes model clauses on the Act in all of its contracts with suppliers, subcontractors and consultants requiring compliance with the Act permitting termination for breach.
6. Evaluating Bouygues’ effectiveness
We have not found any evidence of practices that violate the Code of Ethics or Anti-slavery policy including the values that relate to modern slavery and human trafficking.
We have principles that assist decision making in the event of a breach of standards, for example a requirement to address any breach immediately and for a full investigation to follow. We are currently creating a more detailed process for addressing non-compliance.
7. Training in relation to slavery and human trafficking
Bouygues is developing a programme of slavery and human trafficking awareness training for its procurement team and the individuals in its business with responsibility for managing suppliers in medium to high risk areas.
The purpose of training will be to raise awareness of slavery and human trafficking as a problem that could potentially affect Bouygues’ supply chain, provide assistance in identifying medium and high risk suppliers and behaviours and provide for detailed understanding of Bouygues’ procedures in relation to medium and high risk suppliers.
This Statement was approved by the Board of Bouygues (UK) Limited on behalf of Bouygues, on 16 May 2017. It was reviewed and approved by each of the individual entities comprising Bouygues which has obligations under the Act.