This statement sets out the actions that Grundon Waste Management Ltd has taken during the financial year 1 October 2020 to 30 September 2021 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 within 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 750 people, Grundon Waste Management operates predominantly in the South of England across 12 sites solely within the United Kingdom and provides 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-party providers presents a higher risk.
We 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.
Our Grievance Policy contains a mechanism for employees and workers to report general concerns.
Steps Taken to During the Reporting Period
During the reporting period, we have taken the following steps against the key reporting areas as outlined in section 54(1) of the Modern Slavery Act 2015:
- Anti-Slavery & Human Trafficking Policy
We have developed an Anti-Slavery & Human Trafficking Policy which outlines our ongoing commitment to tackling modern slavery and human trafficking and the steps that we will take. It includes a commitment to ongoing training and raising awareness amongst our workforce, along with the mechanisms to report any concerns.
- Grievance Policy
Our Grievance Policy has been reviewed and revised to include a mechanism for reporting concerns under whistleblowing.
During 2021, we engaged with Stronger2gether to help raise awareness of the risks of modern slavery to our Directors, Senior Leadership Team and key operational management.
As well as training key staff in 2021, we have raised awareness of modern slavery issues at key sites by displaying appropriate literature in multiple languages, in order that employees and workers can identify and report any concerns that they may have in relation to modern slavery and human trafficking to the relevant authorities and organisations, as well as accessing help and support.
As part of our due-diligence, recognising that labour providers pose a higher risk with regards to modern slavery and human trafficking, we have engaged with Fast Forward, an ethical labour standards improvement programme, to support our Managed Service providers in their recruitment and employment practices.
Commitments for 2021/22
During the 2021/22 financial year, we are committed to:
- rolling out awareness training to all employees via internal training and our Induction programme.
- working with our Managed Service provider to embed best practice methods in respect of employment
- launching our Anti-Slavery & Human Trafficking Policy.
- further developing 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 developing 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.
1 February 2022