Modern Slavery Statement

Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes F M Conway’s slavery and human trafficking statement for the financial year ended 31 March 2019. It covers the activities of F M Conway Ltd and its wholly owned subsidiaries1. We are committed to achieving the highest level of ethical standards and to implementing sound governance arrangements to ensure integrity and objectivity in our business activity. We embrace the principles of fairness, inclusion and respect in everything we do. 

Our Business

F M Conway is a leading infrastructure services company delivering vital services in transportation, the built environment and open spaces for communities and business. We undertake our services through our self-delivery model and combining our in-house Consultancy Services team with front line operational excellence, we inspect, design, build, produce, enhance and maintain essential infrastructure services for the community.

The company’s (including its subsidiaries) turnover for the year ending 31 March 2019 was £317.4 million.

Our Supply Chain

F M Conway uses a wide range of suppliers who supply goods for sale and/or who provide services to our business and our customers.  We have in excess of 2000 suppliers and subcontractors supporting our business that are predominately (99%) based in the UK.  Of FM Conway’s direct spend in 2018/19 less than 0.05% was spent with suppliers in high risk countries of origin (countries being determined as high risk by the Global Slavery Index).  Where our audits elicit evidence of non-compliance with the standards we have established, we will support our suppliers to achieve improvement and adherence to our key performance indicators; in some cases, we accept that this may not be possible, and our business relationship may need to be brought to an end.

Our Policies 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our Code of Conduct reflects our position of zero tolerance of modern slavery and human trafficking in any form and reinforces our commitment to acting ethically and with integrity in all our business relationships.

Our Ethical and Sustainable Procurement Code sets out our standards with respect to buying goods and services; as well as detailing requirements with respect to human rights, child and forced labour and modern slavery, this forms part of our contractual relationship with our suppliers.

We are committed to achieving the highest level of ethical standards and strive to ensure integrity and objectivity in our business activity.  It is the company’s responsibility to provide employees and members of our supply chain with a safe and confidential mechanism to raise concerns and report breaches of our standards, processes or protocols. Our Whistleblowing Policy provides a mechanism for our employees to report any concerns or suspected breaches of our policies. 

During the year we launched our Speak Out helpline and application that enables employees and others to raise concerns or to seek advice on a mater related to compliance with the law, our published business ethics and our company Code of Conduct, directly with the business.  The Speak Out helpline is for all employees and for third parties with whom the Company has a business relationship (including employees, contractors, customers, suppliers and agents) if they observe wrongdoing or wish to raise concerns.

Due Diligence Process

We continue to carry out detailed due diligence checks on our supply chain, to include reviewing for risks of modern slavery and human trafficking.  We have systems to identify and assess any area of potential risk of transgression of our business ethics in our own company and our supply chains, and to protect whistle blowers.

Risk Assessment
 

We are aware that risks can arise from modern slavery and human trafficking from all aspects of our business, notably through our recruitment practices (including subcontracted employees), operational site management and supply of materials. We carry out risk assessments regarding our supplier and subcontractor chain to ensure that they are compliant with the Modern Slavery Act.  Where issues are identified (including through our audit processes) that are not resolved to our satisfaction, we would review the on-going nature of the relationship. Appropriate actions are taken, including but not limited to, the removal of any non-compliant organisations from our approved supplier list where there are issues identified that remain unresolved.

Our effectiveness in combating slavery and human trafficking

As part of our ongoing commitment to combating modern slavery and human trafficking, we have established an internal audit department. This function will review our procurement processes across the organisation to highlight any potential risks and mitigating actions concerning modern slavery.

We are a signatory to the Gangmasters & Labour Abuse Authority Construction Protocol, and improved our whistleblowing process to ensure that it is accessible to a wider audience, both internally and externally through our Speak Out helpline and application.

Training 

To ensure greater understanding of the risks modern slavery and human trafficking presents to our supply chains and our business, detailed training on modern slavery is provided to those responsible for procurement and more general business ethics training (encompassing modern slavery) is given to our teams.

Our business ethics are publicised internally and to our supply chain, and we have introduced a means by which both internal and external concerns can be reported to the business.

Our Journey 

We understand that the risk of modern slavery and human trafficking is not static, and we must continue to improve our mitigation in the years ahead to ensure the company is alert to, and acts upon, emerging industry risks.  As part of our continued commitment to improving compliance with the Modern Slavery Act 2015 we are embarking on the following initiatives:

Our Policies:

  • An on-going review of our policies to ensure our workforce understand that our business is committed to acting ethically and with integrity, reflecting our position of zero tolerance with any form of modern slavery or human trafficking.

Our Supply Chain:

  • Review of our pre-qualification questionnaire and suppliers’ terms & conditions to re-enforce our commitment to anti-slavery and human trafficking and to ensure this message is embedded within our supply chain.
  • A review of our subcontracted labour terms & conditions to reflect our position of zero tolerance with any form of modern slavery or human trafficking.

Staff Awareness:

  • To launch and maintain a company-wide campaign that actively promotes the ‘signs to spot’ which may indicate modern slavery is present in our supply chain.  The initiative will encompass the whole workforce and be publicised to all employees and our subcontracted workforce.
  • Promote the ‘signs to spot’ that may indicate a worker is at risk of being exploited at our weekly company induction events.
  • Continue to update training material and raise awareness within our existing workforce in a variety of languages that ensures training is accessible to whole workforce.
Approval

This statement has been approved by the Board of F M Conway Ltd and is signed on its behalf.

Michael Conway MBE
Chief Executive Officer

1 Subsidiaries:  F.M. Conway Building and Maintenance Limited; Conway Minerals Limited; Hawbury Cleansing Limited; The London Paving Company Limited; Heathrow Asphalt Limited; Berkshire Macadams Limited; Hampshire Macadams Limited; United Construction Materials Limited; United Asphalt Limited; United Asphalt (Theale) Limited; United Asphalt (Croydon) Limited; United Asphalt Contracting Limited; United Concrete Limited; Imperial Bitumen; 4 Vector Limited.