Modern-Day Slavery and Human Trafficking Policy

Policy Statement:O'Connell Contracting is a UK-based construction contractor committed to combating modern-day slavery and human trafficking. We are dedicated to upholding the highest standards of ethics, human rights, and social responsibility. This policy outlines our commitment to eradicating modern-day slavery and human trafficking in our operations and supply chains, as required by the UK Modern Slavery Act 2015.

1. Scope:This policy applies to all employees, contractors, subcontractors, suppliers, and other business partners engaged by O'Connell Contracting within the UK.
2. Definitions:a) Modern-Day Slavery: Any form of forced labor, human trafficking, debt bondage, or servitude, where individuals are exploited through coercion, deception, or abuse.b) Supply Chain: The sequence of activities involved in the production, distribution, and delivery of goods or services, including the sourcing of raw materials.
3. Responsibilities:a) O'Connell Contracting: The company shall take full responsibility for implementing and enforcing this policy. The designated representative, such as the Human Resources Manager, will oversee its implementation and ensure regular reviews and updates.

b) Employees: All employees must familiarize themselves with this policy, report any concerns related to modern-day slavery or human trafficking, and actively participate in related training programs.

4. Compliance with Laws and Regulations:a) O'Connell Contracting shall comply with the UK Modern Slavery Act 2015 and other relevant legislation addressing modern-day slavery and human trafficking.

b) The company shall continuously monitor legal requirements to ensure compliance and promptly address any identified gaps or changes in legislation.

5. Due Diligence and Risk Assessment:a) O'Connell Contracting shall conduct regular risk assessments to identify potential areas of modern-day slavery or human trafficking within its operations and supply chains.

b) These risk assessments may include analyzing the nature of work, recruitment processes, geographical locations, and countries of origin of suppliers, contractors, and subcontractors.

6. Supply Chain Management:a) Suppliers and Contractors: O'Connell Contracting expects all suppliers and contractors to adhere to the same standards outlined in this policy. Contracts with suppliers and contractors should include provisions requiring compliance with this policy.

b) Supplier Evaluation: The company will assess potential suppliers based on their commitment to combating modern-day slavery and human trafficking. This evaluation may include audits, self-assessment questionnaires, or site visits.

7. Communication and Training:a) O'Connell Contracting shall ensure that all employees, contractors, and suppliers are aware of the policy, its objectives, and their roles and responsibilities in its implementation.

b) Training programs will be provided to employees and contractors to raise awareness, educate on modern-day slavery and human trafficking, and highlight indicators of potential exploitation. Training will also cover the reporting mechanism and protections for whistleblowers.

8. Reporting and Whistleblowing:a) O'Connell Contracting encourages the reporting of any suspicions or incidents related to modern-day slavery or human trafficking. Whistleblowers will be protected, and concerns will be treated confidentially.

b) The company will establish a reporting mechanism, such as a designated email address or helpline, to enable employees, contractors, and stakeholders to report concerns.

9. Investigations and Corrective Actions:a) O'Connell Contracting will promptly investigate any reports or suspicions related to modern-day slavery or human trafficking.

b) If violations are substantiated, appropriate corrective actions will be taken, which may include termination of contracts, engagement with lawenforcement agencies, or other legal remedies as required by the UK Modern Slavery Act 2015.

10. Transparency and Disclosure:a) O'Connell Contracting will publish an annual Modern Slavery and Human Trafficking Statement in accordance with the UK Modern Slavery Act 2015. The statement will outline the steps taken by the company to address modern-day slavery and human trafficking within its operations and supply chains.

b) The statement will be easily accessible on the company's website and will provide relevant information on policies, due diligence processes, training programs, and actions taken to combat modern-day slavery and human trafficking.

11. Continuous Improvement:a) The company will regularly review and update this policy to ensure its effectiveness and alignment with the UK Modern Slavery Act 2015 and other applicable legislation.

b) O'Connell Contracting will actively engage with stakeholders, industry initiatives, and best practices to improve its approach to combating modern-day slavery and human trafficking.

This Modern-Day Slavery and Human Trafficking Policy demonstrates O'Connell Contracting's commitment to eradicating modern-day slavery and human trafficking, promoting ethical practices, and protecting human rights. By implementing this policy, we aim to create a responsible and sustainable construction industry that respects the dignity and well-being of all individuals.

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