mua has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all of our contractors, suppliers and other business partners. We expect them to adopt the same zero tolerance approach to the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
Organisation's structure business and supply chains
We are part of a global, multi-disciplined engineering and construction company. J Murphy & Sons Limited is the main trading company of the Murphy group of companies (“the Group”). The Group has around 3,500 employees worldwide and operates in the United Kingdom, the Republic of Ireland and as part of a joint venture in Canada. The Group had a global annual revenue of more than £1 billion in 2020.Our supply chains include in the region of 4,087 suppliers, with around 250 of these suppliers accounting for 80% of our expenditure on a regular basis. Our direct suppliers are predominantly UK or EU based and support our business in the provision of labour, plant, materials, equipment and professional services.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain's.
We take responsibility for conducting and growing our business in a safe, sustainable and responsible manner. We understand the impact our activities can have on the environment and society around us, and endeavour to ensure we eliminate or mitigate the risk of negative impacts and leave a positive legacy in the communities where we work.
We have committed to a Sustainability Strategy with specific targets around Climate Action and Social Value make sustainable decision making an integral part of the way we do business. We also have policy statements in relation to Group Sustainability, Sustainable Procurement and Corporate Social Responsibility, all of which are available internally and to our supply chain.
We have signed the Construction Protocol with the Gangmasters and Labour Abuse Authority (GLAA) and with other members of our industry to support the objective of eradicating slavery and labour exploitation in the sectors. The Group has also signed the Supply Chain Sustainability School’s People Matter Charter that commits us to ensuring that basic human rights are protected and exploitation in the workplace is eliminate.
Our Anti-Slavery Policy sets out our approach to modern slavery and applies to everyone working directly or indirectly for or with us. We recognise that appropriate training on modern slavery and the use of forced, compulsory or trafficked labour will increase awareness among our people as well as mitigating the risk within the business and the supply chain.
Due diligence processes
Modern slavery compliance is an integral part of our supplier approval and re-qualification processes. As part of our supply chain accreditation process, we require our supply chain to comply with the Modern Slavery Act 2015. We include our Anti-Slavery Policy in our contracting processes to ensure our supply chain are aligned against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.
We use standard industry accreditation schemes to certify our supply chains’ compliance with modern slavery requirements. This is carried out on an annual basis.
Risk assessment and management
We recognise that the construction sector has particular risks relating to modern slavery and is one of the sectors where the GLAA has the most referrals and cases to investigate.
We consider the following key risks relating to modern slavery for our business are:
- The multiple tiers in our supply chain where goods which may be manufactured in jurisdictions which have greater risk of forced labour or child labour.
- Supply of labour through agencies or other third parties which is subject to coercion and under the control of organised criminals.
- Engaging direct labour which is subject to coercion and under the control of organised criminals
We manage these risks:
- By committing our direct supply chain to complying with our Anti-Slavery Policy
- By selecting responsible providers through a proper due diligence process and continued engagement with them on their labour resources
- By right to work and other identity checks on commencement of employment
We believe training and education of our workforce and supply chain is a critical tool in managing the risk of modern slavery. We also believe auditing our supply chain partners compliance with our policies is another important tool in managing the risk of modern slavery.
Key performance indicators to measure effectiveness of steps being taken
We have adopted the following KPIs to measure our effectiveness in assessing and managing the risk of modern slavery in the coming year:
- 95% completion by employees of the Code of Conduct e-learning module in 2021
- Carry out tool box talk on the risks of modern slavery on all sites in 2021 to cover all operatives
- 1 supply chain event for each of business units to engage on the risks of modern slavery
- Audit supply chain, labour agencies and security companies
Training on modern slavery and trafficking
We recognise that appropriate training on modern slavery and the use of forced, compulsory or trafficked labour will increase awareness among our people as well as mitigating the risk within the business and the supply chain.
Our Code of Conduct forms part of our induction process for all new starters and is a compulsory training requirement for existing employees within the business. It explains what modern slavery is and informs our people that it is their responsibility to help prevent, detect and report incidences of modern slavery. It advises our people to raise concerns about incidences of modern slavery through management or our independent confidential helpline managed by Safecall.
We are partners of the Supply Chain Sustainability School through which we provide specific training to our procurement team on the relevant legislation. Our procurement team also take the CIPS ethics course annually.
We have included in our tool box briefings to our projects a specific briefing on modern slavery advising our people on the warning signs to look out for where there may be incidences of modern slavery and advising them how to report any concerns.
Processes for reporting slavery and human trafficking
The business’ approach to the prevention of modern slavery has stakeholder buy in from the highest levels of management within our organisation. The policy has been considered and formally ratified by the board. The Company Secretary and General Counsel is the appointed Compliance Officer.
The Compliance Officer is responsible for dealing with concerns about compliance with the Act and protections in place for anyone who brings matters of concern to our attention.
We are satisfied that we have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistleblowers.
We have no reason for concern in relation to any current member of the supply chain and their compliance with the Modern Slavery Act.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to all companies in our Group including our parent company, Drilton Limited and our subsidiary companies, Land and Marine Engineering Limited and Murphy Plant Limited.
It constitutes our Group's slavery and human trafficking statement for the financial year ending 31st December 2020 and outlines the steps we have taken as an organisation to assess our operations and supply chain and mitigate any risk of slavery and human trafficking.
John Murphy, Chief Executive Officer
J. Murphy & Sons Limited