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Modern Slavery Act

This statement demonstrates the steps Bagnalls has taken and continues to take to
eliminate the risks of slavery, forced labour, human trafficking, and exploitation, within
our business and that of our supply chain.

Organisational Structure & Supply Chain

We recognise that our responsibility for human rights, labour conditions and anti-slavery
encompasses:

• Our Group and Branch Network– Our staff are directly employed and based in
the UK. We do not normally undertake work overseas. We are a fair employer
and ensure that our company values and policies are communicated to all
employees.

• Our Supply Chain– It is our aspiration that the working conditions throughout our
supply chain meet internationally accepted standards of human rights and
working conditions. Audit and assessment processes are carried out across our
supply chain to ensure their commitment to the requirements of the Modern
Slavery Act.

• Our Customers– We are an ethical business and continue to meet the high
standards of our customers by achieving the required assessment criteria and
meeting the demands of independent, external audits. We also comply with
customers’ Codes of Conduct and policy requirements.

Policies and Meeting the Requirements of the Modern Slavery Act, 2015

Bagnalls’ policy on Human Rights and Labour Conditions has been updated to reflect
our responsibilities under the Modern Slavery Act, 2015 and our commitment to acting
ethically and with integrity in all our business relationships.

• The Board of Directors have overall responsibility for demonstrating, through
clear and visible leadership, that human rights are integral to the way we do
business.

• The Directors are also responsible for monitoring compliance with the policy in all
aspects of our business.

• Managers and supervisors provide visible leadership that promotes human rights
as an equal priority to other business matters.
July 2021

• We also believe that all our employees are responsible for helping to ensure that
we operate free from human trafficking, human rights abuses, slavery, and forced
labour.

• Colleagues are encouraged to bring forward, in confidence, concerns that they
may have about any abuse, via our Whistleblowing Policy.

Internal Processes including Risk Assessment

We have established business practices, which are regularly reviewed, to prevent
slavery, forced labour, human trafficking and exploitation in our business:

• Bagnalls has undertaken a thorough Risk Assessment to identify and assess
potential risk areas in our business. It details the potential risks, who could be
harmed and how, the control measures in place, and how they will be checked.

An annual review is undertaken to ensure that the risk assessment and controls
are in place and being adhered to.

• We conduct checks to ensure our employees have the right to work in the UK
before commencing employment with us;

• We directly employ our people rather than using agencies to provide labour,
wherever possible;

• We pay wages which exceed the minimum wage;

• We promote our Whistleblowing Policy to all employees to encourage them to
openly report concerns about slavery, forced labour, human trafficking,
exploitation, or other human rights abuses; and

• We provide training to employees to understand the issues of forced labour,
slavery, and trafficking and what they should do if they suspect these issues may
be occurring on sites where they work.

Due Diligence Processes – Vetting our Supply and Subcontract Chain

As part of our initiative to identify and mitigate risk we have taken steps to eradicate any
slavery or human trafficking in our supply chain. We therefore acknowledge our duty to
continually review and monitor our supply chain and subcontractors.

The Government has recognised the construction sector as being a high-risk industry for
modern slavery and associated issues. As such, our continued focus is vetting and
monitoring those subcontract companies who supply us with specialist labour trades to
support our contracts.

Regular vetting and auditing takes place to:

• Monitor, review and update our approved supplier/subcontractor vetting process;

• Ask all current subcontractors/suppliers to detail their processes for vetting their
labour and what steps they have taken to prevent slavery, forced labour, human
trafficking, and exploitation in their business and that of their supply chain;

• Develop long-term relationships within our supply chain, especially
companies/individuals who hold similar values to ourselves;

• Remove subcontractors/suppliers from site and/or our approved suppliers’ list
where concerns are raised, until further investigations take place.

Training on Modern Slavery

• To ensure a high level of understanding of the risks of modern slavery and
human trafficking in our business and our supply chains, we have an ongoing
training programme in place to ensure 100% of our permanent employees are
trained in our respective policies and procedures.

• Furthermore, we maintain a target of 100% compliance by subcontract
companies supplying us with specialist labour and key suppliers of products to
complete a questionnaire which details their vetting processes in relation to
modern slavery.

Focused Objectives for 2021-2022

• We have reinforced our commitment to our legal obligations by registering with
the Government’s Digital Registry, to promote further the positive steps Bagnalls
is taking and to send a strong signal to our customers and shareholders about
the value of transparency. Modern slavery statement registry – GOV.UK

• Joanne Gualda, Director, with the support of the Board, will remain focused on
maintaining our registration to continually meet the requirements of the Modern
Slavery Act, 2015.

• As a company, we will continue to monitor the effectiveness of our training and
vetting processes, making changes where necessary to remain legally compliant
and to demonstrate best practice as a responsible employer.

Stephen Bagnall

Group Managing Director

26.7.21

or call Head Office
on 01274 714 800