Modern Slavery Statement

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 Ltd, Onyx Project Services Ltd and HBMS Cladding Ltd) 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 30th November 2022.

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 Project Services Ltd– 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 Cladding Ltd – 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 & Bradford. 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. In 2020/ 2021 our regional Procurement teams mapped our product supply chains and created a tier structure. The HB Projects Group’s products and services are managed by our Central Commercial Director, supported by regional Procurement,

Compliance and Commercial teams.

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:

• Procurement Policy
• Code of Ethics and Business Conduct Policy
• Supplier code of conduct
• Supplier Terms and Conditions – goods only and hire
• Subcontract Terms and Conditions
• Service Level Agreements
• 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.

Right to work verification

Right to work checks are conducted in accordance with current legislation and the government code of practice on preventing illegal working.

These checks form part of our mandatory ‘HR onboarding’ and are conducted for all new workers before they join the Company, and they allow us to identify any foreign workers and their nationalities.

We carry out two types of checks: manual document-based checks and online checks using the Home Office online right to work checking service where applicable. The manual checks are performed in accordance with the Home Office ‘Employer’s guide to right to work checks’ and include obtaining, checking, copying, and retaining of right to work documents.

Where possible, online checks are encouraged for those who have one of the following:

• a biometric residence permit.
• a biometric residence card.
• status issued under the EU Settlement Scheme; 16
• a digital Certificate of Application to the EU Settlement Scheme issued on or before 30 June 2021.
• status issued under the points-based immigration system.
• British National Overseas (BNO) visa.
• Frontier workers permit.

In cases where the individual refuses the use of the online service, the checks are conducted manually.

Individuals who have time-limited permission to work in the UK are subject to follow-up checks the frequency of which depends on the documents provided. Follow-up checks are conducted manually or via the online right to work check where applicable, irrespective of the type of check originally conducted.

The HB Group has documented controls to demonstrate compliance with Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006. These controls include established procedures to control several aspects of the documents summarised as below:

• Identification of the right to work documents (in accordance with the Home Office ‘Employer’s guide to right to work checks’)
• Storage on the Company electronic document management system (LINK)
• Protection via internal access controls and in line with GDPR
• Retrieval for audit purposes by the authorised users
• Established retention periods (during employment and for two years after)
• Automatic disposal on expiry of retention period

Due diligence processes

HB Projects Limited have standard sub-contractor contractual terms which include obligations of sub-contractors to gain the CHAS Advanced accreditation. This accreditation assesses health and safety arrangements and verifies anti-bribery, environmental and modern slavery obligations of the sub-contractor.

HB Projects Limited has its Corporate Social Responsibility management systems assessed separately by Sedex and Ecovadis. The assessments are based upon international ESG standards such as Global Compact Principles and the International Labour Organisation (ILO). We are currently able to indicate a structured and pro-active ESG approach with engagements/policies and tangible actions on major ESG issues, with detailed implementation information.

Annual reviews are undertaken of service level agreements for our category A suppliers by HB Projects internal procurement team and the CHAS Advanced accreditation is reviewed daily by CHAS and our internal procurement and compliance team.

Onyx and HBMS have an internal due diligence process to verify their supply chain management system.

We understand that our biggest exposure to modern slavery is in our product and raw material supply chains. A Pre-qualification accreditation process for suppliers was established in 2021 and the due diligence and monitoring of these suppliers continue to objectives for 2023 and 2024 with the aim to move to a third-party accreditation system, similar to that used with Sub Contractors.

We also have SLA’s in place for our key suppliers, particularly where we are hiring equipment as well as for the waste brokers that we use.

Performance management measurement criteria of our consultants and sub-contractors continues to be
an objective of 2023.

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 continued aim for 2023-2024 is to map our subcontractors, suppliers, and consultants to assess the
above risks along with preventative steps taken.

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. For 2023 this training will be more specific and detailed.

All our internal buyers have completed or are undertaking CIPS training which includes a module on ethical trading, modern slavery and CIPS Code of Conduct.

Our aim for 2023 is to continue with our employee and sub-contractor information forums to create awareness of modern slavery. We are also enhancing in house training for modern slavery awareness and action.

Actions in 2022

• Developed and implemented a HB Projects Group Procurement Policy.
• Mapped our product suppliers and created a tier structure with key performance indicators.
• Mandatory requirement for all sub-contractors to have CHAS Advanced accreditation implemented.
• Set up an internal Sustainability team who have modern slavery as an action item

Further Steps

Commitment for 2023

• Explore third party Pre-qualification accreditation/ process for suppliers.
• Conduct Subcontractor information forums which include information on awareness of modern slavery
• Map our supply chain to modern slavery risks along with preventative steps taken.
• Create a modern slavery training programme, which will be mandatory for all employees to access and complete periodically.
• Formalise processes to investigate and report any suspected modern slavery breaches, together with an action plan for mitigation

Commitment for 2024

• Extend supplier compliance and ethical standards training/awareness.
• Performance management measurement criteria of our suppliers, consultants’, and sub-contractors.
• Create learning hubs for our employees and supply chain on ESG subjects.

Ed Beck, Joint Managing Director