Introduction

Modern slavery includes: Slavery, servitude, forced labour and human trafficking. Modern slavery is fundamentally unacceptable within the operations of the HB Projects Group (HB Projects, Onyx and HBMS) and our supply chains. The HB Projects Group is committed to making sure modern slavery is not taking place within our operations. This statement applies to the financial year ending 28th February 2020.

About the HB Projects Group

The group includes: HB Projects Ltd is a forward thinking, innovative and multi-disciplined Principal Contractor. HB Projects provide a diverse range of construction solutions from concept and design through to on- site delivery and post-completion. Onyx - specialise in store fit outs and all aspects of Retail Project Management – including, planning, procurement, technical advice, installation and liaison with the client and Principal Contractor. HBMS - Specialists in roofing and cladding systems for industry and commerce.

Structure and supply chains

The HB Projects Group has a Head office in Bradford; HB Projects has three regional offices based in Gatwick, Bradford and Livingston. Onyx has a regional office in Sunderland. HBMS is based in Bradford. Construction sites are throughout the United Kingdom. Our supply chain is divided into three separate areas: Sub-contractors, consultants and suppliers. Product and raw material suppliers are complex involving a number of different manufacturing processes.

Supply chain transparency is a priority for the HB Projects Group. The importance of this is recognised by our objective for 2021/2022 to map our product supply chains and create a tier structure. The HB Projects Group’s products and services are managed by a central Procurement Manager, supported by regional Procurement, Compliance and Commercial team.

Policies on modern slavery

Based on values-led leadership, we continually develop our management systems and service delivery to ensure we operate responsibly. Our values are Innovation, Honesty, Quality and Teamwork. Documents relevant to preventing modern slavery within the HB Projects Group, operations include:

• Supplier code of conduct
• Subcontract Terms and Conditions
• Service Level agreements for sub-contract labour only/recruitment/agency workers
• Employee handbook
• Equality and Diversity Policy
• Whistleblowing Policy
• Discipline and Grievance Policy
• Anti-bribery Policy

All documents have been reviewed during the financial year to ensure they are up-to-date with Human Rights and are available to all employees on our electronic HR management system.

Due diligence processes

This year the HB Projects Group have amended their standard sub-contractor contractual terms to include obligations on sub-contractors to gain the CHAS Premium Plus accreditation. This accreditation assesses health and safety arrangements and verifies anti-bribery, environmental and modern slavery obligations of the sub-contractor. All our sub-contractors will have CHAS Premium Plus by 1st March 2021 (the original date of 1st November 2020, had to be amended due to the impact of the Pandemic – COVID-19)

Annual reviews are undertaken of service level agreements by HB Projects internal procurement team and the CHAS Premium Plus accreditation is reviewed by CHAS and our internal procurement and compliance team.

We understand that our biggest exposure to modern slavery is in our product and raw material supply chains. The due diligence and monitoring of these suppliers are objectives for 2021 and 2022 (respectively).

Performance management measurement criteria of our suppliers, consultants and sub- contractors is an objective for 2022.

Risk assessment

The HB Projects Group recognises that there is a risk of modern slavery in any area of our business where there is the potential for:

• Migrant labour
• High presence of refugees
• Contract and agency workers
• Child labour and young workers
• Women workers

Our aim for 2021-2022 is to map our supply chain to assess the above risks along with preventative steps taken. For 2022-2023, we will address further commitments.

Measuring effectiveness

Our management systems all work to the Plan, Do, Check and Act cycle. We are very much in the early stages of identifying our modern slavery risks (plan) within the organisation. We will identify and understand our area of greatest risk, where our actions can have a positive impact and measure our effectiveness once established within our procurement processes.

Training

The HB Projects Group undertakes awareness training for all employees; a modern slavery awareness film is shown to all new starters in their company induction with Directors. All our internal buyers have completed or are undertaking CIPS training which includes a module on ethical trading.

Our aim for 2021 is to continue with our sub- contractor information forums to create awareness of modern slavery and to develop an internal purchasing policy and develop our internal procurement team’s knowledge further on ethical trade and purchasing practices.

Actions in 2019-2020

• Updated policies to include modern slavery commitments.

• Introduced awareness of modern slavery within our new starter induction.

• Reviewed service level agreements to include responsibility of modern slavery for labour only contractors/recruitment and agency workers.

• Implemented new supply chain accreditation scheme CHAS Premium Plus; requires verification of a sub- contractor’s modern slavery commitments.

Further Steps

Commitment for 2020-2021

• Develop a HB Projects Group Procurement Policy – which will include ethical trading requirements.

Commitment for 2021-2022

• Map our product supply chains and create a tier structure.

Map our supply chain to modern slavery risks along with preventative steps taken.

Commitment for 2022-2023

• Extend supplier compliance and ethical standards training.
• Performance management measurement criteria of our suppliers, consultants and sub-contractors.