BAM Nuttall Modern Slavery Statement 2020
BAM NuttallModern Slavery Statement 2020
BAM Nuttall LtdModern Slavery TransparencyStatement 2020The BAM Nuttall Board make this statement onbehalf of BAM Nuttall and its subsidiaries for thecalendar year 2020. It sets out what we are doingto stamp out slavery and human trafficking in ourbusiness and our supply chain, and the progressmade since our last statement.In preparing this statement and considering ourplans, the potential impacts of COVID-19 havebeen considered. It has been over a year since thepandemic began and we can see that the actualimpacts of COVID-19 in our world are far reachingand all encompassing. Specifically for modernslavery, we believe there is an increased risk ofunfair treatment and low paid workers in our supplychain in the wake of COVID-19 and extra vigilance isneeded to help stamp out slavery. In considerationof the restrictions that were imposed during 2020 asa result of the pandemic, we will adapt our actionsin 2021 accordingly.Proactive ownership‘I take the initiative to prevent,rather than fix’Predictableperformance‘I deliver what I promise’Scalable learning‘I ask, listen and support,so that we learn collectively’Open collaboration‘I share, so we all gain’Our business and valuesBAM Nuttall is a part of the Royal BAM Group nv,a construction and civil engineering enterpriseoperating in Europe and internationally employingmore than 18,000 people globally. BAM Nuttallemploys in excess of 3,000 direct employeesin the UK. We operate primarily in the UK andhave collaborated with our sister company, BAMConstruct UK, in developing our approach to stampout slavery.The Company undertakes civil engineering worksacross sectors including rail, road, energy, water,coastal and ground engineering, through threedelivery centres – Transport, Major Projects andRegions. More information about what we do can befound at: bamnuttall.co.uk/workWe are committed to being a sustainable businessand ultimately want to have a net positive impact onclimate, resources and people by 2050.The BAM values are the guiding principle by whichwe conduct ourselves and our business whichhelps to build sustainable success. Our valuesunderpin what we do and help to create a culture ofaccountability, responsibility and collaboration on arange of issues, including modern slavery. They areadopted in the BAM Code of Conduct which, alongwith our policies and procedures, support the waywe tackle modern slavery.We strive to enhance people’s lives acrosscommunities where we operate. This includesthe way that BAM is involved in tackling modernslavery within the civil engineering and constructionindustry – going above and beyond what we areasked to do to help make a difference.BAM Nuttall is committed to collaborating withits stakeholders to combat slavery and humantrafficking throughout our operations andthose associated with our business. This is not astandalone issue, but one that forms part of ourapproach to ensuring that we:Modern Slavery Statement 2020Page 2 of 10
treat people with fairness, dignity and respect; source goods and services responsibly; promote and strive for transparency; and conduct our business with the highest regard toethical and environmental standards.We are committed to ensuring that all of ouremployees and third parties performing services foror on our behalf and / or our joint venture partnersabide by the highest professional and ethicalstandards.Supply ChainOur Supply Chain Purpose is ‘To create and maintainethical and sustainable collaborative relationshipswith supply chain partners, embracing coreBAM values, which generate mutually beneficialoutcomes through early engagement and marketleading delivery on projects’.BAM Nuttall continues to collaborate with BAMConstruct, and other Royal BAM Group OperatingCompanies to develop together and, where possible,to align business excellence in shared pursuits. Areasthat BAM Nuttall and BAM Construct are currentlycollaborating on include supply chain categorisationand category management. In terms of any jointcategory management efforts BAM Nuttall andBAM Construct commit to including modern slaveryprevention and ethical procurement practices beingpart of those efforts.Currently, the BAM Nuttall supply chain is large dueto the complexity, work scope and geographicalspread of our projects. To meet our customers’needs we have a diverse supply chain and in2020 we worked with some 3,700 vendors. Thiscomprises approximately 2,350 suppliers, 1,350subcontractors. BAM Nuttall spent about 520mdirectly with the supply chain in 2020. As manyof our major infrastructure projects are deliveredwith the help of joint venture partners, our truesupply chain spend was considerably more. Ingeneral terms our supply chain spend representsModern Slavery Statement 2020approximately 80% of BAM Nuttall turnover; thisclearly demonstrates the importance of our supplychain and we endeavour to work with a supply chainthat has similar values to ourselves.Of further significance is that in excess of 20%of supply chain spend was with our BAM Linkvendors. BAM Link is an agreement with ourpreferred vendors which provides a commitmentto collaborate to work more closely together in astrategic manner and to have a common focus onethical business.Whilst we recognise the potential impact thatmodern slavery may have on our complete supplychain and their individual suppliers we are initiallyconcentrating our efforts on BAM Link vendorsand higher risk members of our supply chain. Wehave BAM Link agreements with both suppliers ofmaterials and goods and with subcontractors:Materials and GoodsWe consider ethical and sustainability criteria whensourcing materials and goods and work with ourcustomers to assist them in selecting sustainableand ethically sourced materials. When we providedesign services, or procure materials and goodsdirectly, we specify to industry standards forresponsible and sustainably sourced /produced material.This includes timber to FSC / PEFC standards andrecognised responsible sourcing certifications forother materials, such as BES6001 and ethical supplystandards, such as dimensional stone from suppliersoperating to ETI base code guidelines.Our Sustainable Business Policy and Ethical BusinessPolicy outlines our commitments and minimumrequirements to procurement and how we conductour business. These, alongside our Code of Conduct,ensure a robust policy based approach to tacklingmodern slavery.Page 3 of 10
Subcontractors and service providersWe subcontract to specialist trade subcontractors,temporary labour and staff providers, designconsultants and other specialists to service ourbusiness needs, working across different parts ofthe business spanning a wide range of skill levels.Specialist trade subcontractors will often source andsupply their own materials and goods. In such cases,we insist on sustainable and ethical standards thatcomply with our policies.supply chain or manufactured from countries with ahigher risk of modern slavery.Spend in 2018 - 2020 hotspot categoriesHotspots and risks ofexploitationAt BAM Nuttall, we take a risk based approach totackling modern slavery and are aware that ourmanagement of risk is crucial in our effort to tacklemodern slavery. It is recognised and acknowledgedthat one of the most significant risks in our supplychain is exposure to low skilled or migrant labour.This risk was clearly identified in the spend analysisand resultant gap analysis undertaken with ActionSustainability. Having undertaken some actions(detailed below) in respect of the first five categoriesidentified in our 2018 Modern Slavery Statement(i.e. temporary labour, operated plant, temporarystaff, mobile crane hire and fencing works) andacknowledging that progress was limited in 2020,our belief remains that the labour intensive sectorsare at the highest risk of exploitation.Spend in 2019 and 2020 hotspotcategories2020 spend in additional categoriesidentified in 2019 statementWhilst we continue to work with and monitor thesefive categories, as stated in our 2019 Modern SlaveryStatement, we will continue to undertake spendand risk analysis of further categories within oursupply chain namely site security, formwork, steelfixing and concrete placing, scaffolding and steel gritblast and painting (‘The 2020 Categories’). Thesecategories have a history of trade associations thatencourage proper employment practices. As suchinitial analysis suggests that there is a lower risk ofmodern slavery.We continue to review and enhance our assessmentprocesses for products that are sourced by ourModern Slavery Statement 2020Page 4 of 10
What we did in 2020 and whatwe plan to do in 2021Following our 2018 Modern Slavery gap analysiscarried out in collaboration with BAM Construct UKand Action Sustainability, we determined an actionplan and implemented it in 2019. In general, weachieved the actions and progress we had planned.These were focused on the three key areas to stampout slavery: industry engagement education complianceThe impact of COVID-19 on some of our plannedactivities for 2020 has delayed the progresswe hoped for in some areas. However, with ananticipated imminent return to a more stableworking environment ahead, in 2021 we intend torefocus and build upon the successes from 2020 andfurther enhance our drive to stamp out slavery.When identifying our actions for 2021 we haveconsidered the challenges that COVID-19 presentsand the need to adapt. We will ensure continuedengagement, learning and knowledge share byattending and organising virtual meetings andindustry forums.Full details of the successes we have achieved in2020 and our objectives for 2021 are set out below.Modern Slavery Statement 2020Page 5 of 10
Industry EngagementBAM Nuttall considers industry engagement to be a fundamental component in the drive to stamp out slavery.Through engagement with our supply chain and wider industry, we aim to improve knowledge share anddevelopment of wider anti-slavery measures.During 2020 our plans were affected by COVID-19, including the fact that many of our employees werefurloughed or working from home for large parts of the year, a restriction on face to face meetings and strictlimitations on travel. Despite not achieving some of our planned actions, we are proud of our achievementsin the face of this adversity and made further steps to achieve the goals we set for ourselves in our mission tostamp out modern slavery.20202021 We continued to fully support and promoteindustry events showing our commitment tostamp out slavery. Risk assessments of the next focus tradesidentified in the Gap analysis will be developed. We collaborated with our peers through theSupply Chain Sustainability School to collectivelyimprove industry performance on sustainabilityissues, including modern slavery. We progressed discussions with a potentialcharity that supports modern slavery victims. In collaboration with BAM Construct, weidentified differences in our prequalification andonboarding requirements in modern slavery. We will hold an event with the new trades andlabour providers following the completion ofthe tender process. Our expectations for theiractions in relation to modern slavery will beaddressed and the resources we have available toassist them will be communicated at the event. We will continue to seek industry events to fullysupport and promote, showing our commitmentto stamp out slavery. We will continue to collaborate with our peersthrough the Supply Chain Sustainability Schoolto collectively improve industry performanceand training on sustainability issues, includingmodern slavery. We will continue to investigate the link betweenBuilders Profile and Construction Line (BAMConstruct prequalification provider) to align themodern slavery requirements.KPI: To help support victims of modern slavery we will Identify and support an appropriate charity bythe end of 2021.Modern Slavery Statement 2020Page 6 of 10
EducationBAM Nuttall considers education to be a fundamental component in the drive to stamp out slavery. Througheducation both within our business and our supply chain, we aim to promote the awareness and reporting ofall suspected incidents of modern slavery.As with our goals for industry engagement, COVID-19 impacted our ability to achieve some of our educationalgoals. Many of our furloughed employees were unable to participate in training initiatives and working fromhome made delivery of our face to face “tool box talks” challenging. Nevertheless, our eLearning scores didincrease in 2020 which evidences our continued commitment to training in 2020 where and when it waspossible.20202021 We added modern slavery e-learning andtool box talks to our employees’ mandatorytraining requirements. 1,210 of our employeescompleted the training. We will continue to monitor and promotetraining to achieve a minimum 80% completionby our employees. Projects displayed our awareness posters andused our tool box talks. BAM Nuttall held 1 supply chain event and howwe can stamp out modern slavery was a keyelement of this event. We continued to promote the Supply ChainSustainability School to our supply chain and wereviewed our supply chain usage of the School’smodern slavery training. 40 of our key supplypartners undertook a total of 330 individualtraining modules provided by the School. We will develop and implement acommunications plan to further increaseawareness around modern slavery and theactions we are taking. We will consider introducing a Modern SlaveryInformation hub on our intranet, to provide arange of resources that all of our sites and officescan use, such as posters, tool box talks andworkshop materials.KPI: Engage in two modern slavery specific communications with our supply chain with the aim of increasingawareness of modern slavery challenges and how we can work together to stamp out slavery.Modern Slavery Statement 2020Page 7 of 10
ComplianceBAM Nuttall considers compliance to be a fundamental component in the drive to stamp out slavery. Throughthe determination of controls, prequalification checks and audits both within our business and our supplychain we aim to continually improve the effectiveness of our measures to prevent modern slavery.National and local lockdowns introduced to combat the COVID-19 pandemic rendered face to faceengagement and on site auditing a challenge to complete in the last 15 months. We were unable toimplement our audit plans for 2020 but we remain committed to getting these back on track for 2021.Notwithstanding the challenges we had, we were able to carry out some virtual auditing with our suppliers tosupport our compliance goals.The unexpected duration of the pandemic, and consequential business disruption, also meant that we wereunable to finalise a modern slavery specific risk assessment on the potential impacts of COVID-19. Our generalrisk management for the business considers, assesses and monitors the impacts of the pandemic and thegeneral risks to the business.20202021 We concluded the temporary labour tenderprocess. We will prepare our audit questions for thetemporary trades and labour category inreadiness for the conclusion of this tenderprocess. Our vendor assessment process was extendedto encourage the use of the Supply ChainSustainability School modern slavery training. Review, update and issue our Policy Statementsfor Ethical Business and Sustainable Business. A modern slavery interview was carried out withone of our site security suppliers. We will consider the potential need for aseparate modern slavery policy and implement ifappropriate. We will commence work on a response protocolto provide minimum requirements for site teamsand guidance on what to do should an instanceof modern slavery be identified. We will evaluate the need for materials vendorsto undertake a full vendor registr
Modern Slavery Statement 2020 Page 2 of 10 BAM Nuttall Ltd Modern Slavery Transparency Statement 2020 The BAM Nuttall Board make this statement on behalf of BAM Nuttall and its subsidiaries for the calendar year 2020. It sets out what we are doing to stamp out slavery and human trafficki
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3 Climate-induced migration and modern slavery Contents About the authors 4 Acknowledgements 5 Executive summary 6 Chapter 1: What is ‘modern slavery’? 11 1.1 What is modern slavery and what forms does it take? 11 1.2 Who is impacted and at risk? 12 1.3 Drivers of modern slavery 13 Cha
PROFESSOR DESMOND L. NUTTALL A TRIBUTE. Thi; hook is dedicated to Desmond Nuttall who died in October 1993, at the age of 49. Desmond was an outstanding educational researcher whose influ-
operations through its supply chain. AC3 primarily addresses the risks of modern slavery practices occurring in its operations and supply chain through its newly formed Modern Slavery Policy. This policy takes a risk and materiality approach to identifying and investigating potential modern slavery within the businesses operations and supply chain.
modern slavery and human trafficking within our business. As required by the Modern Slavery Act 2015 (the "Act"), this statement describes the steps that the Phoenix Group has taken during the financial year ended 31 December 2019 to prevent modern slavery from taking place in our supply chains and within our own business. 2
modern slavery and human trafficking and by 2025 end child labour in all its forms.4 With the goal firmly set, governments, businesses and campaigners have joined the fourth anti-slavery movement to help eradicate slavery for good.5 However, technological advancements for data collection on modern slavery could hold the key to end this fight.
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