This statement sets out the actions that Grundon Waste Management Ltd has taken during the financial year 1 October 2021 to 30 September 2022 to identify all potential modern slavery risks related to its business and the provisions made to ensure there is no slavery or human trafficking within the business or our supply chain.
As part of the Waste & Recycling sector, we recognise the risks of modern slavery and human trafficking associated with our industry and understand our responsibilities to take a robust approach to slavery and human trafficking. Grundon Waste Management is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational Structure & Supply Chain
Directly employing over 800 people, Grundon Waste Management operates from 12 sites solely within the United Kingdom, predominantly in the South of England, providing a total waste management service for the reduction, reuse, recycling, recovery and disposal of waste, delivered via a combination of specialist services, contract management and the operation of our own facilities.
Our supply chain includes other waste and recycling businesses, as well as a number of businesses who supply goods and services to Grundon. Additionally, we supplement our own workforce with labour procured through third-party providers, and although we have steps in place to ensure third-party labour providers are assessed against their obligations in relation to the Modern Slavery Act 2015, we recognise that the provision of labour through these third-parties presents a higher risk.
Grundon operate the following policies that support our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Our Recruitment Policy sets out how we conduct our recruitment process, including carrying out relevant checks to ensure as far as possible, that an individual is not subject to human trafficking or modern slavery.
Selection & Approval of Recruitment Agencies and Suppliers (Temporary Labour), and Selection & Approval of Contractors and Suppliers
We are committed to ensuring that our suppliers adhere to the highest standards of ethics.
Recruitment Agencies and Suppliers who provide labour to Grundon are required to provide examples of how they adhere to their obligations towards preventing modern slavery and human trafficking, and outline their recruitment and selection methods, through our compliance questionnaire. Where Managed Service contracts are in place, we ensure that there are provisions within the contracts that stipulate our expectations towards the recruitment and employment of workers, including the use of second-tier suppliers.
All appropriate suppliers and contractors are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Any contractor or supplier, including recruitment agencies and labour providers, who acts in an unlawful manner will have their contract terminated immediately and will be removed from the Company’s approved supplier system.
Our Compliance and Human Resources teams periodically review our policies and procedures as our knowledge and understanding of the risks of modern slavery and human trafficking develops.
Steps Taken to During the Reporting Period
Within the 2020/21 reporting period, we outlined that we had engaged with Fast Forward, part of Stronger Together, to support our Managed Service provider in their recruitment and employment practices.
During the 2021/22 reporting period, key personnel from both the provider and Grundon attended in-depth training around the Fast Forward auditing methodology and core standards, and an audit of the labour standards of the provider later took place, with the results provided to Grundon in June 2022.
While no instances of modern slavery were uncovered through the audit, Grundon nevertheless made the decision to put the Service out to tender and subsequently awarded the Managed Service contract to a new provider in November 2022. Key to this decision was to ensure that any new provider could demonstrate a proactive approach within their working practices to preventing Modern Slavery. Our new provider is committed to ethical working practises, demonstrated throughout their bid.
Commitments for 2022/23
- Embed the new third-party provider, and undertake an initial Fast Forward audit and gap analysis of the new provision,
- Further develop procedures, processes and awareness in order to better assess the risks of a supplier or contractor in relation to preventing modern slavery and human trafficking.
- Further develop policies and procedures to ensure our own internal processes support best practice in relation to preventing modern slavery and human trafficking.
This statement is published on our Company website and will be reviewed annually to ensure ongoing compliance and with our obligations under the Modern Slavery Act 2015 and has been reviewed and approved by the Board of Directors.
24 February 2023