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Policy Statement: Modern Slavery Act 2015

Introduction

Workman LLP recognises that slavery and human trafficking remains a hidden blight on our global society. The Firm’s aim is to identify our responsibility by being alert to the risks, however small, in our business and in the wider supply chain. Staff are expected and encouraged to report concerns to management, whom in turn are expected to act upon them.

Our Business

Workman LLP is the largest, independent, specialist commercial property management and building consultancy firm in the UK.  With more than 650 staff across a network of 11 UK offices, Workman has focused purely on these disciplines for 35 years which has been the foundation of the Firm’s sustained, steady growth. Workman have an internal supply chain to support our business activities and also employ a considerable supply chain on behalf of clients, providing a variety of goods and 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 Statement 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 chains.

This Policy takes into account, and supports, the policies, procedures and requirements documented in our Integrated Management System, compliant with the requirements of ISO 9001:2015, ISO 14001:2015 and OHSAS 18001:2007.

The implementation and operation of these management systems underlines our commitment to this Policy Statement. Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached.

Additional procedures ensure that this Policy is understood and communicated to all levels of the Firm, and that it is regularly reviewed by the Partners to ensure its continuing relevance to the Firm’s activities.

Due Diligence and Risk Assessment

The Firm will achieve these aims by our initiative to identify and mitigate risk in the following ways (but not limited to):

  • Stringent vetting and investigation of our supply chain (contractors, policies, Contracts etc);
  • Continually audit and review our practices for checking all employees are paid at least the minimum wage and have the right to work;
  • We encourage the reporting of concerns and the protection of whistle blowers;
  • The Firm will not knowingly support or deal with any business involved in slavery or human trafficking;
  • We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values and also check their own supply chains.
  • 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;
  • Completion of Audits by Partners, Directors and external Auditors;
  • Use of labour monitoring and payroll systems within the Firm; and
  • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Our policies to mitigate risk include:

Equal Opportunities

We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities. Recruitment policies also ensure equal opportunities are offered.

Whistleblowing policy

We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals

Supplier Code of Conduct and Procurement Policy and Procedures. Our approach to procurement and our supply chain includes:

  • Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
  • Requiring that the main contractor provides details of its sub-contractor(s) to enable robust checks on their credentials
  • Randomly request that the main contractor provide details of its supply chain
  • Using a standard Supplier Selection Questionnaire that has been introduced (which includes a section on Modern Day Slavery)

Training

Advice and training about modern slavery and human trafficking is available on Workman’s Hub and is also discussed at our compulsory staff induction training. Details are also available in the Procurement Policy and Procedures in respect of supply chain management, which is perceived as our most significant risk.

We are looking at ways to continuously increase awareness within the Firm, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.

Measuring the Effectiveness of this Policy

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
  • Our own and third party audits show no incidents or breach of policy
  • Our supply chain can demonstrate the same robust procedures as Workman.

This Policy is in accordance with Section 54 (1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement, including Workman Facilities Management Limited and Workman FM Ltd which are both wholly owned by Workman LLP.

GDPR sub-processors

When delivering client services, Workman LLP will act as a data processor and accordingly comply with its obligations under the General Data Protection Regulation.

To deliver these services, Workman LLP may need to engage third parties (sub-processors). On this page, Workman LLP maintains the list of its General Suppliers and Property Management Suppliers who may sub-process personal data under an agreement with Workman LLP.

General Suppliers

When delivering client services, Workman LLP relies on a number of suppliers to support its own infrastructure and administration. The suppliers act as a sub-processor.

Type

Subtype

Names

Email and communication

Collaboration

Data Centres

Microsoft

Microsoft

All Internal

Information Technology Archival and Disposal

IT Support

Workman LLP Applications

Analytics and performance

Digital Marketing

Computer Waste, Flexistore

All Internal

Trace Solutions

Google Analytics and Lead Forensics

Concep

Website Website hosting

Outsourced Business Operations

Copying & Printing

Couriers

OAK

Barclays, Cascade

Toshiba

Royal Mail and others

Operations

 

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Property Management

In addition to the above, Workman’s Property Management teams will engage other suppliers or subcontractors. Although the use of these suppliers or subcontractors will depend on the actual property and type of management, the primary and most common sub-processors are listed below.

  1. Information Technology
  2. Property Finance – Trace Solutions, Microsoft
  3. Helpdesk, KPI and PPM – Internal
  4. Incident Reporting – Internal
  5. Contract Management – Internal
  6. Professional Advisory
  7. Health and Safety – Ark Workplace Risk Ltd – Quooda, William Martin Compliance Solutions Ltd – Meridian
  8. Accountancy – Various
  9. Incident Management – Internal

Further details about any relevant property specific sub-processors can be provided on request through your Workman LLP contact.