Modern Slavery and Human Trafficking Policy
1. Policy Statement
BVI Building Services & Controls (the "Company") is committed to driving out modern slavery and human trafficking from within our own business and our supply chains. We maintain a zero-tolerance approach to modern slavery, human trafficking, forced labour, and similar human rights abuses.
We are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all our contractors, suppliers, and other business partners.
2. Scope and Responsibility
This policy applies to all persons working for the Company or on our behalf in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
The Management Team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
3. Supply Chain Risk & Controls
As a building services and controls provider, we recognise that the construction, engineering, and facilities management supply chains can carry inherent risks of modern slavery. These risks are primarily associated with sub-contracted site labour and the procurement of components (such as electrical, HVAC, and automated control systems).
To mitigate these risks, the Company operates the following controls:
Right to Work Checks: We conduct robust checks on all direct employees to ensure they have a legal right to work in the UK, are paid at least the National Living Wage, and have control over their own bank accounts and documentation.
Supplier Vetting: We expect our direct suppliers and sub-contractors to confirm their compliance with the Modern Slavery Act 2015. When sourcing temporary or agency labour, we only work with reputable, licensed recruitment agencies.
Contractual Terms: Where applicable, our standard terms and conditions require suppliers and subcontractors to declare that they do not engage in forced labour or human trafficking.
4. Employee Training and Awareness
We are committed to ensuring our workforce can identify the warning signs of modern slavery, which may include:
Individuals who do not have control of their own identification documents.
Workers who appear frightened, withdrawn, or unwilling to communicate.
Unusual drop-offs or collections of large groups of workers at project sites.
Individuals lacking proper Personal Protective Equipment (PPE) or appropriate clothing for the task.
Information on modern slavery risks is integrated into our company policies and onboarding processes to maintain high awareness across our operational sites.
5. Reporting Concerns (Whistleblowing)
The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us.
Employees must raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.
Concerns should be reported directly to a Director or line manager.
The Company encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicions.
6. Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy or fail to take corrective action when requested.