Modern Slavery and Human Trafficking Statement
1. Turnbull Overview
From design and build to facility management and maintenance, we provide a sustainable, end-to-end solution for large scale engineering projects.
As part of the YTL Group, we were established to support the installation and operation of utilities for Hinkley Point C, the first nuclear power station project in the UK for 20 years. Today, however, we are applying our tried and tested approach to all kinds of utilities and infrastructure projects -helping clients save money, reduce waste, and add long-term value to local communities and the wider economy. To us, it is simply the right (and the only) way to do things, a blueprint for the successful construction, operation, and maintenance of projects.
2. Our Policy
Turnbull is committed to meeting the aims of the Act and a work environment that is free from human trafficking, slavery, servitude and forced or compulsory labour. Turnbull strongly opposes slavery and human trafficking in its supply chains and in any part of its business.
Turnbull embeds the principles of the Act within all appropriate internal policies and procedures, including its whistleblowing and anti-bribery policies, to operate responsibly and ethically as a business. Our Group Procurement Policy, our Group People Policy, our ethics, and our core values outline our commitment to acting with integrity in all our operations and ensuring people are treated with dignity.
Turnbull provides a fair, safe, and inclusive place to work for our employees and our supply chain, supported by our governance framework that is:
- Aligned with good practice such as (but not limited to) the United Nations Guiding Principles on Business and Human Rights; The Chartered Institute of Procurement and Supply (CIPS); and Home Office guidance.
- Supported by a company-wide risk assessment for the Board. This assesses all risk across the group including that of modern slavery, across our supply chain and employees. Following our business-as-usual checks and controls we have a low-risk environment.
3. Our Supply Chain
Turnbull continues to build and maintain longstanding relationships with trusted suppliers, making clear its expectations of business behaviour. Modern Slavery forms part of our supplier selection and vetting, with all suppliers expected to demonstrate their commitment to compliance with the Act, treating their workers and their ongoing supply chains fairly and free from enslavement. Turnbull is committed to making a positive and sustainable impact on society which includes a commitment to tackling modern slavery.
Turnbull's supplier base is predominantly UK-based. All suppliers are vetted by standard procurement processes that include a variety of checks and reviews designed to comply with all applicable laws and regulations, including the Act. Modern slavery clauses are a key criterion included in contracts and purchase order standard terms and conditions and require suppliers to assure that they and their supply chains meet their obligations under the Act and demonstrate the steps taken to monitor compliance.
YTL Group companies are a member of Utilities Against Slavery (formerly known as Utilities Modern Slavery Working Group) which is made up of representatives from the 26 gas, water and electricity providers working together with the support of the Slave Free Alliance to eradicate Modern Slavery from the utilities sector.
These measures seek to verify that suppliers meet their obligations under the Act and where required, demonstrate the steps they have taken to monitor compliance.
4. Our People
Turnbull has a strong purpose and value led culture that drives what we do and how we work. These values and behaviours are embedded into our company's recruitment processes, vacancy adverts, contracts of employment, and interview techniques at all levels of the company.
Turnbull rigorously checks that all its employees have the legal right to work in the UK and the same rigour is applied to agency and temporary workers. We have recently updated our company induction and onboarding process. We consider the overall risk of modern slavery and human trafficking to be low due to the nature of our embedded values, culture, and the level of checks we have in place.
Turnbull employees receive the statutory employment rights to which they are entitled and are paid at or above the minimum wage. There are also processes and programmes in place which seek to create not only a safe, fair, and inclusive working environment, but also one that supports wellbeing and learning. We also work closely with our trade unions.
As well as setting out the rights and benefits which are available to Turnbull employees, published policies, employee handbooks and individual contracts of employment make it clear what actions and behaviours are expected of them.
Turnbull has an established Raising a Concern process that provides a free 24/7 helpline to raise any concerns, including but not limited to bullying, harassment or any suspected illegal activity including entrapment, human trafficking or other employee or contractor concern. The helpline is widely communicated to all staff and all concerns are taken seriously and investigated.
Staff working in areas that are more exposed to modern slavery risks such as procurement, commercial, HR, finance and customer teams are asked to undertake training each year covering financial crime and modern slavery.
5. Modern Slavery Risk
Turnbull has assessed modern slavery risk as low and maintains an active review over its operations. It has not uncovered evidence of slavery and human trafficking within its own operations or those of its suppliers.
This statement will be reviewed on an annual basis.
6. Authorisation
James Dryden
Managing Director
Turnbull Infrastructure and Utilities Ltd.
Date: 14th August 2024