Modern slavery and human trafficking policy statement
This policy statement sets out the approach Charis Group and its subsidiaries (“Charis”) has taken to date and those Charis intends to take throughout the 2022 financial year with the aim of ensuring that modern slavery or human trafficking is not taking place within our business or within our supply chain.
Charis structure, business and supply chain
All Charis Group companies rely upon this statement, where necessary, for the purpose of complying with their individual annual reporting requirements of the Modern Slavery Act 2015. The approach and processes referred to within the statement are relevant to all Group companies and Charis will continue to monitor performance in complying with the Act’s requirements as a basis for future annual statements.
Charis is an international consultancy and construction company, providing programme and project management, cost consultancy, construction delivery and facilities management services. Charis works from five strategic hubs in Europe, Middle East and North Africa, the Americas, Asia Pacific and Sub-Sahara Africa. Our global supply chain comprises contractors, service providers, producers of materials and manufacturers of a variety of mechanical, electrical and other products used in professional services and the construction process.
Integrity is one of the core values of Charis. Charis is committed to being a responsible business and upholding high ethical standards in all our operations, including those provided by our supply chains around the world.
Charis operates across a range of business sectors and services, and our approach to pro-actively addressing the risks of modern slavery reflects local context and the service Charis offers. Our four principal areas of business operations are as follows:
- Develop – responsible for procuring and managing a diverse supply chain including professional teams, contractors and operators.
- Construct (including Charis Interiors, Charis MEP, Charis Logistics and Charis Tech) – responsible for managing contractors and suppliers (materials and labour) in the supply chain and the on-site workforce.
- Consult – responsible for project management and working with clients, overseeing design and procurement teams and managing client requirements and specifications.
- Operate – responsible for facilities management stags and employed to procure and supervise suppliers on behalf of our clients.
Our direct responsibilities under the Act cover Develop, Construct and Operate. In Consult the responsibilities lie primarily with our clients and their directly contracted delivery partners.
Our primary risk area is within the highly tiered supply chain structure relating to construction delivery. Therefore, achieving transparency of labour employment arrangements and sourcing of materials are key challenges.
The Group Chief Executive, Sharon C Packiamuthu, is the Charis Executive Board member responsible for oversight of the Charis approach to eradicating modern slavery from business operations. The Responsible Business (RB) team, procurement team, legal team and human resources team each support implementation of the Charis approach to tackling modern slavery. Each of these teams works across our different business sectors, geographies and services.
Charis has working relationships with unions and police forces around the UK in relation to preventing modern slavery and works alongside partners as well as charities to help implement our approach.
Charis policies in relation to slavery and human trafficking
Charis has made a number of commitments and developed policies designed to help us eradicate modern slavery. These include:
- Management systems ISO9001:2015, ISO14001:2015 and OHSAS18001:2007; which include procedures and guidance documents outlined below
- External facing Slavery and Human Trafficking Policy Statement Ref MG-ENV-PL-009.
- Internal facing policy Ref MG-ENV-PL-002
- 2030 Charis Business Strategy
- MG-ENV-GD-077 Modern Slavery – Guidance on Supervision referenced in AG0260
- MG-ENV-GD-076 Modern Slavery – Guidance on Procurement referenced in MG-ENV-PR-040 / AG0315
- Master Subcontract Annex MP-PC-FM-006 – covering minimum contract requirements tackling modern slavery
- AG0315 - Sustainability Management Activity Instruction
- Responsible Business Construction Delivery Procedures & Guidance - MG-ENV-PR-040
- Charis Speak Up whistleblowing reporting service and supporting procedures
Identification of risks, together with steps taken to prevent and manage those risks, and due diligence processes in relation to slavery and human trafficking in business and supply chains
The Global Slavery Index provides significant evidence that labour standards risks could be present in construction and property supply chains, in the production of construction materials, delivery of construction activities and through the provision of professional services equipment such as laptops and phones. To identify and mitigate the risks of slavery and human trafficking, Charis makes informed decisions regarding the procurement and management of labour, goods and services, utilising the following:
- Clear definition and contractual terms setting out our expectations of our suppliers (as listed in our policies listed above).
- Identification of issues and risks (using Supplier Ethical Data Exchange) to inform all the detailed and accurate procurement decisions
- Achilles Building Confidence and other prequalification tools to assess UK contractor and supplier compliance; and further due diligence of international suppliers. These tools assess suppliers against labour standards, physical health and safety, environmental and business ethics criteria, identifying issues and risks.
- Training and supplier development
- Compulsory training for all Charis staff and construction supplier leadership teams on slave labour and human trafficking risks and how to spot the signs of potential issues
- Collaboration with our clients, peers and suppliers (Charis is a member of the Gang Master Labour Abuse Authority construction protocol).
- Charis Speak Up whistleblowing reporting service and supporting procedures
Where Charis acts in a Consult capacity, Charis advises our clients of the 2015 Act requirements and provides relevant guidance on the associated modern slavery risks in their supply chains
Where staff have concerns around issues of forced labour, human rights, recruitment practices or exploitation, they are encouraged and expected to report concerns to management via a confidential phone number or online reporting service. This is part of the Charis Speak Up policy operated by Charis Group. All reports will be investigated by Charis group and the Charis Group Legal Director.
2022 key steps taken
- Slave free Alliance Construct site assessments and follow up activity
- Each Charis Engine (our operating entities) and Group Services nominated a responsible individual for tackling modern slavery to form a joint working group created/led by the Group Director for Corporate Strategy
- Construct conducted a number of &Wider direct worker reporting surveys
- Construct held Hope for Justice engagement surgeries
- Conducted Industrial Relations audits
- Operate enhanced their standard terms and conditions to reflect best practice
Where any issues are identified, Charis works with suppliers to seek resolution through training and development. If the issue is deemed serious and/or is not capable of remediation, Charis will remove the supplier from our supply chain until the issue is fully resolved.
Effectiveness in ensuring that slavery and human trafficking is not taking place in business or supply chains, measured against appropriate KPIs
Our business strategy contains KPIs which link to the eradication of modern slavery, including:
Construction
- 100% of directly procured construction materials will be responsibly sourced by 2024, and transparency of provenance secured for 80% of all other materials, goods and services.
- 100% tier 1 contractors to be signed up by 2025
- Projects will host and run multiple informative events to encourage employee engagement.
- Recruitment agencies will be certified to the Joint Industry Board standard and will sign up to responsible recruiter principles
- Charis will conduct worker modern slavery surveys on projects.
- A system such as PpAC-iD (Passport Authentication Check) to improve/automate checking of employees’ rights to work will be adopted.
- Charis will investigate all reported incidents and take the appropriate action
- 100% Charis staff will complete the Modern Slavery E-learning training.
All Charis activities
Training and capacity building
Charis’s Company Handbook was completed in 2022 and forms one of the compulsory handbooks to be read and followed during new starter probationary periods. This company handbook was also rolled out to our existing global workforce. At end 2022, ~95% of all staff (directly employed and contractors) had completed the handbook. This handbook is further reinforced through other training and initiatives that have been rolled out across Charis including:-
- Inclusion of Modern Slavery Learning in Sustainable Construction training, which is mandatory for all Construct and Consult teams
- Charis Group of Companies has provided awareness training and safety standards for construction sites.
- Provision of multi-language posters and helpline information on all construction sites.
- Inclusion of modern slavery content in the Charis company induction for all new starters.
- Addition of modern slavery issues to our whistleblowing and escalation processes in our Speak Up policy
2023 plans
Further to the initiatives in the section above, in 2023, Charis plans to continue our work under the four key work streams. Activities will include:
- A series of eradicating modern slavery Charis group events for our construction supply chain partners
- Further industrial relation audits focusing on tackling modern slavery
- Partner with more charities to attain project level Slave free Alliance membership
- Annual EcoVadis scoring with the aim of Gold
- Continued promotion of company handbook and its standards on modern slavery
- Further audits and internal audits on modern slavery
- Further charity worker engagement and education
- Increased use of document checkers to combat forged documents and improve workers’ access to documentation.
During 2023, Charis will increase workforce engagement, both within our own operations and throughout our supply chains to create open and transparent forums that will allow site workforces to raise issues around modern slavery and human trafficking.
About this policy statement
This policy statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Charis slavery and human trafficking statement for the financial year ending 31st March 2023.
Approved by the board