This document contains MYC’s policy on modern slavery and human trafficking and its statement under s.54 of the Modern Slavery Act 2015.
Forced or compulsory labour, human trafficking and other kinds of slavery represent some of the gravest forms of human rights abuse in any society. We all have a responsibility to be alert to the risks in both the MYC business and our supply chain.
MYC is committed to conducting all aspects of its business in an ethical and transparent manner. We acknowledge our duties and responsibilities under the Act.
MYC values require that all workers are treated with dignity and respect. We are fundamentally opposed to slavery, human trafficking, forced labour, debt bondage, the sale or exploitation of children and all exploitative practices in the workplace.
MYC requires that all contractors and suppliers do not engage in any such practices, and do not knowingly themselves contract with third parties which do.
MYC values require that it terminates business relations with any contractor or supplier found to be in breach of anti-slavery and human trafficking obligations.
Modern slavery statement
This statement is made by MYC on its own behalf.
Our statement sets out the approach that MYC has either already taken during the financial year to 6 December 2019, or intend to take during the current financial year, to prevent modern slavery and human trafficking in its business and supply chains.
MYC is a dynamic construction services company. Our people specialise in fit out, technology, construction and development and are dedicated to delivering places that help people and businesses thrive.
With a turnover of c. £86 million for the financial year ended 31 March 2019, and an employee base of just under 1,000. Our operations are solely based in the UK.
MYC employee overview
We are committed to providing a great place to work and this is at the heart of our business strategy. We comply with local minimum age and wage laws and do not employ child labour.
All our employees are:
• paid by bank transfer; we do not allow payment to be made into third party bank accounts, thus minimizing the risk of forced or compulsory labour; and
• vetted for the right to work in the country where they are employed. Where employees require a work permit/VISA we ensure they have the necessary documentation in place.
As a responsible employer, we take the welfare of our employees seriously. Our whistleblowing policy encourages employees to report wrongdoing (including exploitation) in any form.
Supply chain overview
The MYC business model means that we work in partnership with a large number of sub-contractors and other suppliers to fulfil our commercial and contractual obligations to our customers.
In common with many companies operating in the construction industry, our supply chain is complex; there are often many tiers of suppliers between MYC (as the main contractor) and the source of the raw materials and labour we use.
We have adopted, or are in the process of adopting, various procedures to ensure that both our existing and potential supply partners understand our values, standards and requirements regarding the prevention of modern slavery and human trafficking within supply chains.
We are aware that the biggest slavery and human trafficking risks for MYC lie in our supply chains, particularly the supply chains of our subcontractors in higher risk jurisdictions.
As part of our sub-contractor due diligence procedures, during the past year we have incorporated an additional vetting process into our sub-contractor due diligence procedures. All potential new subcontractors who go through our prequalification process are now required to sign up to our ‘anti-slavery and human trafficking supply chain commitment’ before they can be classed as an ‘MYC approved subcontractor’.
It is our intention that MYC approved contractors, whether based in the UK or overseas, will progressively be required to sign up.
However, we acknowledge there is still more work to do in this area. In addition to our UK approved subcontractors, we also work with a large variety of other suppliers both in the
UK and overseas. We need to gradually ensure that all our supplier groups, wherever they are working, are required to sign up to our Supply
Chain Commitment; further consideration will be given to this during the course of this year.
Training and awareness
An update on modern slavery and the various issues to be aware of is included in our on-site induction training and induction processes.
Relevant employees within the company (to include those working in supply chain, procurement, human resources, health & safety and senior on-site roles) are required to complete a modern slavery and human trafficking training.
This course covers the requirements of the Act and the potential consequences for noncompliance.
We will continue to review and evolve our anti-slavery and human trafficking policies and procedures over time, as we gradually make progress in the adoption of a common approach throughout our business.
Failure to comply
A failure to comply with the Act, and/or this policy statement will be deemed to be a material breach of the terms of our standard commercial agreements and contracts of employment.
This statement is made pursuant to Section 54(1) of the Act and constitutes MYC slavery and human trafficking statement.
Approved by the MYC Directors on 06 December 2019.
For and on behalf of MY Construction & Carpentry Ltd Signed:
Date: 6th December 2019