This statement is made pursuant to Section 54, part 6 of the Modern Slavery Act 2015 and sets out the steps Sharkey has taken in the last 12 months to address the potential for slavery and human trafficking taking place in our business or supply chain.
We recognise modern slavery, as set out in the act and seek to do our part to remove such practices in the construction industry. Sharkey shall never engage with an organisation that does not comply with the Modern Slavery Act. All Sharkey Employees, are paid above minimum wage. We comply with local minimum age laws and do not employ child labour.
Where applicable our employees comply with the working time directive and, where they have opted out because they direct their own work, they are encouraged to work no more than 48 hours per week and to take regular breaks. All our employees are paid by bank transfer and we don’t allow payment to be made into third party bank accounts thus minimising the risk of forced or compulsory labour.
The nature of our business makes it unlikely we would employ mentally vulnerable adults but if this were the case we would arrange for them to have a dedicated carer and high level support from the HR team.
All employees are vetted for the right to work in the country where they are employed, where employees require a work permit/VISA we assist them to procure appropriate documentation.
As a responsible employer we take the welfare of our employees seriously and our Whistle-blowing policy allows employees to report wrongdoing (including exploitation) in any form.
We make reference to our policy on Modern Slavery, Human Trafficking and Exploitation in our Employee Handbook, this statement is available for all to read on the Employee Intranet and is provided to clients or potential clients on request.
The construction supply chain can be complex; there are often many tiers of suppliers between main contractor and the source of raw materials. We have adopted various means to clearly communicate our expectations around human rights and modern slavery to our suppliers. These include:
Prequalification processes. Any potential supply chain member who wishes to be an ‘approved’ partner undergoes a rigorous pre-qualification procedure. This procedure has been updated to include questions around the supplier’s policies and procedures concerning human trafficking and modern slavery.
Commercial agreements. We have updated our commercial agreements with our supply chain to highlight and require compliance with the Act.
We provide training on the legislation to Sharkey employees and selected parts of our supply chain.
The importance of this is such that failure to comply with the Act is a material breach of the terms of our standard subcontract.