Modern Slavery Act 2015 Transparency Statement

Gardiner & Theobald (G&T) provides a wide range of professional construction consultancy and related professional services. This Modern Slavery Act Statement (the ‘Statement’) sets out G&T’s commitment and actions taken to comply with the Modern Slavery Act (MSA) 2015 (and specifically, Section 54 – Transparency in Supply Chains) during the financial year ending 31st March 2024.

ORGANISATIONAL STRUCTURE, COUNTRIES OF OPERATION AND SUPPLY CHAINS

G&T is a limited liability partnership registered at Companies’ House under number OC307124 and is headquartered in London.

PROCESS

Organisations that provide goods or services to G&T are subject to appropriate due diligence. They are required to confirm they and their own supply chains are free from modern slavery (which may also be referred to as human trafficking).

HIGH-RISK ACTIVITIES

The following activities are considered to be at risk of modern slavery within G&T and the list will be reviewed and updated from time to time:

  • Provision of materials supplied to G&T (such as marketing materials) which may be produced in jurisdiction or by organisations that are not compliant with the MSA 2015. 
  • Use of staff by suppliers to G&T, where the supplier’s processes may not be compliant with the MSA 2015.
  • Employment of sub-consultants, suppliers and sub-contractors by G&T, where their work practices may not be compliant with the MSA 2015.

RESPONSIBILITY

Responsibility for G&T’s anti-slavery initiatives is as follows:

  • Statement: The Statement has been drafted by key personnel, and has been endorsed by G&T’s Managing Partner and Management Board.
  • Investigations: G&T has included specific questions in its due diligence enquiries for new and existing sub-consultants, suppliers and sub-contractors.
  • Training: A training programme is available to ensure understanding of modern slavery. The internet-based training resource is available for all of the G&T Group, both in the UK and overseas and, where necessary, appropriate sub-consultants, suppliers and subcontractors.
  • Right to Work: G&T uses an identity validation scanner to verify the validity of staff identification documents, and establish their legal right to work in the UK.

RELEVANT POLICIES

G&T has implemented the following relevant policies:

  • Anti-bribery Policy & Related Business Rules: This Policy clarifies actions and behaviour expected of staff when representing G&T, and incorporates requirements related to the Rules of Conduct of the Royal Institution of Chartered Surveyors (RICS).
  • Whistleblowing Policy: This Policy encourages reporting of any misconduct concerns, including concerns related to the direct activities or the supply chains of G&T. This Policy is designed to make it easy for staff to make disclosures, without fear of retaliation. Employees, sub-consultants, suppliers, sub-contractors, clients or other associated third parties who have concerns may contact G&T’s Managing Partner or Human Resources Partner directly, or may make a confidential disclosure.
  • Recruitment Procedure: G&T uses specified, reputable employment agencies to source staff.
  • Social Value Policy: G&T’s core values are independence, reputation, progression, ethical thinking and engagement.

DUE DILIGENCE

G&T undertakes appropriate due diligence with new suppliers, and regularly reviews its existing suppliers.

PERFORMANCE INDICATORS

G&T has:

  • Developing a system for supply chain verification. Since circa February 2016, G&T has evaluated appropriate potential suppliers before they enter the supply chain.
  • Been reviewing its existing supply chains periodically.

TRAINING AND AWARENESS RAISING

G&T has in place an online training module introduced in October 2016 which it offers to all staff within the organisation (and appropriate suppliers).

This training covers:

  • What the MSA 2015 means to individuals.
  • What is expected of employees with regards to looking out for, and reporting, victims of
    modern-day slavery.
  • How to report suspected cases of modern-day slavery.

BOARD APPROVAL

This Statement covers the G&T financial year ending 31st March 2024, and has been endorsed by G&T’s Managing Partner and Management Board. It will be reviewed and updated annually.

Download a full copy our Modern Slavery Act Statement here.

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