Published On: April 1, 2019

Slavery and human trafficking remains a hidden blight on our global society. We all have a
responsibility to be alert to the risks, however small, in our business and in the wider supply
chain.

Staff are expected to report concerns and management are expected to act upon them.

ORGANISATION’S STRUCTURE

MODERN SLAVERY POLICY

We at Mulholland Contracts Ltd acknowledge responsibility to the Modern Slavery Act 2015 and have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our suppliers and we expect that our suppliers will hold their own suppliers to the same high standards. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors and external consultants.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

RESPONSIBILITY FOR THE POLICY

The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it The Directors have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

COMPLIANCE WITH THE POLICY

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier at the earliest possible stage.

 

COMMUNICATION AND AWARENESS OF POLICY

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk –

  • Where possible we build long standing relationships with local suppliers
  • With regards to national or international supply chains, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.

BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

The Company will not knowingly support or deal with any business involved in slavery or human trafficking.

This policy is effective from 01/04/2024 and will be reviewed in 31/03/2025.

Signed Kevin Breen

Date: 01/04/2024