This Modern Slavery Statement has been published by The Dandara Group for the financial year 2023. In accordance with the Modern Slavery Act 2015 (the Act), this Statement sets out the steps taken by The Dandara Group to understand likely potential modern slavery risks related to our business and to prevent modern slavery and human trafficking in our business and supply chain.
The scope covers activities of the Group within the jurisdiction of the UK, the Isle of Man and Jersey.
The Dandara Group, founded in 1987 includes a portfolio that spans the residential and commercial sectors, across the for sale and rental markets. In the years since the company began, we have developed and delivered thousands of homes and won numerous industry awards. We operate in the Isle of Man, Jersey and across the UK. Our workforce is made up of permanent and temporary, office and site-based roles employed both directly by the companies within The Dandara Group and via our supply chain partners.
At the time of writing, we directly employ 1,005 people within the Dandara Group. In addition, we use the services of Labour Supply Agencies to supply labour, trades and logistics and site services personnel as required across our sites. Furthermore, we have a diverse sub-contractor labour force, supporting over hundreds of sub-contractor companies across our divisions, including groundworkers, housebuilding trades and security personnel.
Due to a range of different contracts that those working with and for us are on, we work with our supply chain partners to ensure that our due diligence extends beyond the first tier of the recruitment process. We apply appropriate employment practices and policies for each jurisdiction we work in and uphold high quality labour standards across the Group.
The following Statement sets out the steps we have taken so far in 2022 – 23 and what we plan to do during 2023 – 24 to advance our objectives around preventing modern slavery and human trafficking. It has been reviewed and approved by Steven Hannah, Director.
The Dandara Group of companies have developed a suite of policies, procedures and commitments that support and respond to our compliance and governance requirements. Where appropriate, these are signed by the Chief Executive of each respective company and available on the relevant website(s). This Modern Slavery Statement forms part of this suite of documents.
Our Commitments outline the expected compliance requirements for workers’ welfare and conditions of employment and are reviewed annually. Our onboarding and procurement processes are aligned with these commitments and thus our supply chain partners are required to abide by this suite of documents as appropriate within each jurisdiction.
Within the Dandara Group, due diligence is carried out to prevent modern slavery & human trafficking. We have recently set up a Working Group, bringing together senior individuals from departments / jurisdictions within the businesses. Individuals from Human Resources (HR), Health, Safety & Environment (HSE), Commercial, Compliance, Construction, Procurement, Legal and Environmental Social & Governance (ESG) have met to discuss and review our current approach to preventing modern slavery within the Dandara Group.
At the very start of the recruitment process, the HR and Recruitment teams carry out due diligence upfront as part of the pre-start employment process for those under the direct employment of the Dandara Group.
In relation to construction site personnel employed through Labour Supply Agencies, recruitment companies or subcontractors as well as those employed directly in the UK by the Dandara Group, all construction site personnel are required to carry up to date Construction Skills Certification Scheme (CSCS) Card in the UK or if in Jersey, complete the required Jersey Safety Awareness Training (JSAT). As well as helping to confirm identity and right to work status, these cards demonstrate a level of competence amongst personnel to safely perform a specific job. Once on site, personnel undergo a Site Induction, which includes the topic of Modern Slavery.
In relation to the recruitment of site / short term workers, in general, the Dandara Group work with several labour supply agencies. We require our labour supply agencies to ensure that staff: are legally able to work within the jurisdictions where we operate; have written employment contracts; and have not had to pay for the opportunity to work. The labour supply agencies subject employees to checks to ensure they are genuine applicants including verification checks. The agencies also operate a supplier / subcontractor verification process which as well as the normal checks also include due diligence and a review of the controls undertaken by the supplier / subcontractor. In the Isle of Man and Jersey, these checks are carried out by our in-house team.
During 2023, our approach to the Pre-Qualification Process (PQQ) across some of the Dandara Group was updated. As part of this revised approach, labour supply agencies are now required to complete the PQQ process including a section on Modern Slavery. Our sub-contractors must also go through the PQQ Process and need to respond directly to questions on preventing of Modern Slavery.In addition, we have recently commenced a review of the labour supply agencies and recruitment companies that we work with to ensure that they carry out their own robust checks in relation to reducing the risks associated with Modern Slavery.
The Dandara Group spends a significant proportion of revenue within our supply chain, through the procurement of goods and or services from our supply chain partners. Our supply chain is an integral part of our operations, and our success and reputation are linked to their performance and ethics. Our supply chain partners range from large global companies to small and medium businesses and social enterprises. The Dandara Group has developed strong, long-term relationships with many of these partners. We understand that construction is a high-risk sector in relation to modern slavery due to complex supply chains and labour practices and we are committed to preventing slavery and human trafficking within our activities and those of our supply chain. For our construction sites, our onsite suppliers are required to go through the PQQ Process which aims to reduce the risk of modern slavery occurring on our sites. Volume suppliers (paper, sundries, consumables, cleaning products suppliers etc) are currently being reviewed with the aim of being included in a future version of the PQQ process. This Statement is published on our website(s) and will be issued in electronic format to suppliers as part of the onboarding process of new suppliers.
All new direct employees that are office and site-based will attend an induction event where the topic of modern slavery is covered along with the response requirements should anyone suspect modern slavery. Existing staff have been recently mandated to complete a modern slavery e-learning module that will enable them to:
- Increase awareness.
- Inform participants how to spot the signs and
- Give participant guidance on what to do in a suspected case of modern slavery.
All sub-contractors and site personnel must go through a site induction process before working on our sites. This site induction includes the topic of modern slavery and attendees must sign that they have understood the process relating to modern slavery and human trafficking.
The HSE Team include a module on Modern Slavery as part of their Toolbox Talks series and the HSE team include modern slavery Information Bulletins as part of their updates to sites.
We know that key activities, such as the procurement of materials, and the use of subcontractors and labour agencies, increase the risk of modern slavery occurring within the construction industry. To mitigate this risk, we state to stakeholders that The Dandara Group we have a zero-tolerance approach to modern slavery and will not work with supply chain partners or source materials from those who do not make efforts to reduce modern slavery risks associated with their own business and supply chain. In addition, we ensure that risks of modern slavery are covered within our PQQ and Onboarding processes. The established Working Group will also help ensure a more comprehensive approach to due diligence and risk mitigation across different jurisdictions and departments.
The following table outlines the identified risks and how Dandara proposed to manage and mitigate these risks.
| Category | Risk to Dandara | Management & Mitigation |
|---|---|---|
| Material Suppliers |
|
We request Modern Slavery compliance check at qualification and during on-boarding process to mitigate this risk. In 2023 / 2024, the procurement teams will examine existing processes to determine if /where exposure to high-risk countries should reduce. |
| Labour Agencies |
|
In the UK, in 2023, our PQQ Process was updated. All Labour Supply Agencies are now required to respond to specific questions on how they are reducing the risk of modern slavery. We understand this is a risk area and have identified the need to raise awareness with supply chain partners of our expectations. This includes carrying out further due diligence such as providing supply chain partners with further communications about legislative requirements such as right to work checks. This work has commenced and will continue in 2023/2024. |
| Subcontractors |
|
Our contracts require all our subcontractors to comply with Modern Slavery regulations. In 2023 / 2024, we will ensure that all sub-contracts will include an electronic copy of our latest modern slavery statement. We will require our subcontractors to ensure they have a written contract of employment between them and their employees. These sub-contractors need to be able to confirm that their employees have not had to pay any direct or indirect fees to obtain work. |
We have evaluated and understand the risks of modern slavery within The Dandara Group and within our supply chain. However, we understand the need to continue to review our processes and procedures and those of our supply chain on a regular basis to enable us to better spot the signs of exploitation.
| Target set in Q2 2023 | Progress to Date / Next Steps |
|---|---|
| Establish Modern Slavery Working Group | Established in May 2023. |
| Review Training and Induction Content | Our Modern Slavery induction and training requirements were recently updated. However, as part of the aim to continue improve, during 2023 /24, Site Managers will be asked to review and implement the principles from ‘How to set up your site to combat Modern Slavery Guidance Document’ (Supply Chain School, May 2020). |
| As part of our Due Diligence Checks, liaise with Labour Supply Agencies and subcontractors on requirements | Commenced and will continue during 2023 – 24. |
| Communications |
Supply Chain: During 2023 / 24, across the Group, we will reiterate our requirements in relation to sustainable procurement, to both local commercial / buying teams as well as our material suppliers. Site Teams: We will actively communicate to sites that we are registered with Stronger Together, an agency which aims to prevent exploitation. Across the Group, information will be provided via the HSE teams on prevention aims & how to report suspected modern slavery. |
| Support SMEs within supply chain with modern slavery requirements | Dandara Group will where appropriate, utilise the resources of external organisations such as Stronger Together or Supply Chain Sustainability School learning pathway to support the SMEs within our supply chain to understand more on Modern Slavery Regulation requirements. |
| Site Audits | During 2023 /24, we will liaise with a third-party auditing company to conduct unannounced site worker audits across the Dandara Group. These are likely to cover direct employees, as well as those employed via subcontractor or labour supply agencies. Our objective is to incorporate findings of these audits into our Due Diligence process. |
From 2023 / 24, we will measure our work on modern slavery against more Key Performance Indicators (KPIs). These are likely to include:
1. HSE Team to develop Vulnerable Persons procedure to assist teams in their understanding of risk and processes. Requirements will be communicated to all site teams.
· KPI: Number of sites to receive notice of this new procedure.
2. Modern Slavery Site Audits: aim to carry out audits across sites.
· KPI: Number of audits completed.
3. Due Diligence Checks of Labour Supply Agencies and subcontractors: aim to ensure Agencies and Contractors are carrying out their own due diligence around modern slavery risks.
· KPI: Number of checks carried out.
There are several ways we encourage those who work with and for us to raise their concerns, based on the level of seriousness. These have been communicated to our colleagues via our intranet and information bulletins across sites within The Dandara Group.
The process includes:
- Immediate safeguarding concerns should be reported to the police on 999.
- Where modern slavery is suspected but there are no immediate safeguarding concerns, parties should report via the whistleblowing phone number or email address. (Specific contact details have been provided on the intranet & information bulletin issued to sites at the release of this Statement).
- Alternatively, concerns can be reported to the Gangmasters and Labour Abuse Authority via 0800 432 0804.
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This statement is made and published in accordance with Section 54 of the UK Modern Slavery Act 2015 and constitutes The Dandara Group’s Modern Slavery and Human Trafficking Statement for the financial year 2023. The content was agreed by the Modern Slavery Working Group and approved by the boards and will be reviewed and updated within six months of the financial year end in 2024.
Steven Hannah
Finance Director
Date: July 2023