1. Introduction
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st August 2022 and 31st July 2023. This statement is pursuant to section 54, Part 5 of the Modern Slavery Act (2015).
The statement sets down Doocey Group’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
2. Organisational structure and supply chains
This statement covers the business activities of Doocey Group which are as follows:
Doocey Group is a multi-disciplined, civil engineering and utility contractor operating nationally. Core services include repair, maintenance, construction and installation of utility and infrastructure assets as well as traffic management. It involves the connection of utility networks to housing and commercial developments. The Company operates to Framework contracts as well as bespoke project work.
• See Doocey Group Scope Policy – DG-PL-1000
As our supply chain involves several entities or projects performed by a prime contractor with a series of sub-contractors, we only exercise control over our relationship with our contractual counter party (normally but not always the prime contractor). Persons who contract with that counterparty will be performing services for the counterparty and not for other persons in the contractual chain.
The Company currently operates in the following countries:
• England & Wales
The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking: We used only approved suppliers and contractors via the Company supplier Approval Process which includes right to work checks for all personnel assigned to Doocey Group Activities. We complete risk based due diligence and the use of anti-slavery terms and conditions in relation to contractual agreements with Counterparties. We will only approve suppliers or contractors whereby they adopt a similar approach with their own supply chain and the next part in the supply chain
3. High Risk Activities
The following activities are considered to be at high risk of modern slavery or human trafficking: Use of subcontractor labour whereby the person is contracted to the prime contractor or for other persons in the contractual chain.
Responsibility for the Company’s anti-slavery initiatives is as follows:
3.1 Policies:
Head of HR & Support Services is responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of the business. The HR department is responsible for implementing and enforcing effective systems and controls designed to ensure modern slavery does not occur in our business and supply chains.
3.2 Risk Assessments:
Head of SHEQ is responsible for risk assessments in respect of human rights and modern slavery by a process of annual review of subcontractor RAMS and Supplier Approval Process documentation. Risk assessments are, therefore, integral to our attempts to eradicate modern slavery in our business and supply chains. In particular, we seek to ensure that modern slavery risk is managed as close to its source as possible, and by the management teams that have the most knowledge and expertise in the business or risk area. Modern slavery risks vary based on the characteristics of each business. The specific manner and methodologies by which these risks are addressed and mitigated vary based upon, among other things, the nature of the risks and of the assets and operations to which they apply, the geographic location of the assets, the economic, political and regulatory environment, and our assessment of the benefits to be derived from such mitigation strategies. While no practices and procedures are capable of identifying and preventing all modern slavery, our risk-based approach is designed to enable efforts to be focussed where they are most needed and can most help eradicate modern slavery.
3.3 Due diligence:
The HR department is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. The SHEQ & Procurement department have a due diligence protocol in place that includes anti-slavery considerations, which applies when engaging or renewing third party suppliers.
4. Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all personnel involved in the appointment of subcontractors to complete online training on modern slavery and human trafficking.
5. Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
5.1 Whistleblowing Policy – DG-PL-5006
The Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
5.2 Business Conduct and Ethics Code DG-PL-1011
The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
5.3 Corporate Sustainable Social Responsibilities (CSSR) Policy – DG-PL-1007
The Company’s CSSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
6. Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers included (on a risk adjusted basis) specific prohibitions in contracts with our direct suppliers against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children;
The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier; invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
7. Performance Indicators
The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including Subcontractor Inductions and Right to Work checks and requiring all relevant staff to have completed training on modern slavery as well as use of labour monitoring and payroll systems and finance records relating to payments to subcontractors.
8. Application & Review
This Policy applies to all Employee’s, Contractors and Sole Traders working on behalf of Doocey Group Limited (#13755588) and all subsidiary Companies detailed; Doocey Multi Utilities Ltd (#13478512); Doocey Groundworks Ltd (#13213273); M&A Doocey Construction Services Ltd (#10715817); Doocey Properties Ltd (#12667622); Doocey Holdings Ltd (#03462107); Doocey Traffic Management Ltd (#03012149); M&A Doocey Plant Hire Ltd (#01762031); M&A Doocey Civil Engineering Ltd (#02426466); Broadhaven Homes Ltd (#08415311); Pipeline Resilience Services Ltd (#13245744); collectively known as “Doocey Group”.
This Policy is shared with employees on induction and is available electronically via the company shared drive.
This Policy is reviewed annually as part of the management review held in accordance with the company’s accredited management systems and on an ad hoc basis were considered appropriate by the Joint Managing Directors, Steve & Mark Doocey.