Anti-Slavery / Trafficking Policy – OKC-ECS-003

1  Introduction

Modern Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the potential risk of their presence, however small, within our business; in particular within our supply chain. Our Staff is expected to report concerns and our management is expected to act upon them. This document clarifies the means in which the company, O’Keefe Construction (Greenwich),

  • Is committed to eliminating slavery and human trafficking from production within our supply chains
  • Identifies and addresses potential pathways for these activities, and
  • Is compliant with part 6 (article 54) of the Modern Slavery Act 2015 (the Act)

2  Organisational Structure

The company’s scope of operation of includes the provision of civil engineering and construction services to the building industry. We specialise in groundworks, heavy civils, reinforced concrete frame, demolition, and associated works. Our group turnover is in excess of the preliminary guideline amount of £80 million.Unusually for the industry, the company employs a substantial proportion of its workforce directly and some additional personnel are employed through agencies. All employees are required to provide evidence that they may legally work within the United Kingdom.
Access to our supply chains is centralised and qualification of suppliers is conducted by our Buying Department prior to order placement for goods and services.

3  Our Policies on Slavery and Human Trafficking

We are committed to ensuring that no slavery or human trafficking exists within our supply chains. This Anti-slavery Policy reflects our commitment to acting ethically and with integrity in our business endeavours. We are determined to implement and enforce effective systems and controls to ensure that slavery and human trafficking does not take place within our supply chains.

4  Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk:

  • Our purchasing activities are centralized through a single department to ensure optimum qualification of new of supply chains;
  • We endeavour to build enduring relationships with local suppliers and make clear our ethical business expectations;
  • We prefer to source raw materials from British or European companies, and we expect these businesses to have reciprocal anti-slavery and human trafficking policies and processes so as to exclude potentially unethical suppliers from the supply chain.
  • We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
  • We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values.

5  Risk identification

Manufactured products that we source are supplied to us in compliance with the Construction Products Regulations 2013 and we view products that bear CE marking to be of low risk.
We occasionally source raw materials relating to our construction activities, such as aggregates but, as these are costly to transport, all such materials are sourced within the United Kingdom..
We have identified two potential pathways where forced or compulsory labour might enter our supply chain:

6  Risk management

Actions taken to reduce the risk of materials manufactured or obtained using forced or compulsory labour entering our supply chains are as follows:

  • Update our Terms and Conditions forbidding the use of forced labour, child labour, or physically abusive disciplinary practices. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.
  • Write to our external labour providers explaining our policy and requesting evidence of a reciprocal policy in the event that that provider’s turnover meets the required threshold or, if not, a statement of assurance that those providers stand with us in this stance.
  • Offer information and training to our decision makers (see next section)

7  Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors and members of our Buying Department have been briefed on the subject. Information shall be made available concerning Human Rights, Basic Working Conditions, and Corporate Responsibility.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the 2017/2018 financial year. This document shall be displayed in a prominent location on the company website.


Chief Executive

Patrick O’Keefe

17th August 2018