Applicable to:

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Parogon Contracts Limited, All Employees, External Consultants, Tradespeople and Suppliers

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1. Policy Statement

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Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We 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 implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (the ‘Act’). We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, 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, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

 

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

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2. Responsible for the Policy

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The board of directors has overall responsibility for ensuring this Policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Managing Director has 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.

 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

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You are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the Managing Director. We will aim to update and build on this Policy throughout the coming years to ensure that our response is as robust as possible to the potential of trafficking or slavery in our supply chains.

 

3. 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 chains 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.

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If you:

• believe or suspect that a breach of this Policy has occurred or that it may occur.

• wish to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier, you must raise it with your manager or the Managing Director or report it in accordance with our Whistleblowing Policy as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, please raise it in any event. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

• believe that you have suffered any such treatment, you should inform your manager or the Managing Director immediately or report it in accordance with our Whistleblowing Policy. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

 

4. Policy Measures

This policy is intended to be specifically tailored to consider the risks associated with the sector in which Parogon Contracts Limited operates in, and the complexity of its supply chains, and the jurisdictions where those in its supply chains are based. For example:

 

The Company is required to comply with high labour standards in relation to its own employees, through the presence of several human resources and other related policies.

Therefore, the greater risk of trafficking or slavery relating to our businesses would not be likely to occur within the Company itself but be further down the supply chain that we use.

• Consultants and advisers.

• Contractors and sub-contractors.

• Suppliers of goods and materials for all stages of the construction cycle.

• Suppliers of plant and machinery.

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We have identified the following areas of the supply chain as comprising the highest risk of slavery and trafficking activities:

• Human trafficking – in circumstances when using sub-contracted labour forces, where coerced/trafficked gangs may be present.

• Slavery and human trafficking – in circumstances when using materials such as ‘conflict minerals’ (tantalum, tin, gold or tungsten), steel, or other raw materials being predominantly sourced from countries with poor records on slavery and human trafficking.

 

To combat the risk from these areas and in any other potential areas where trafficking or slavery may enter our supply chains, we have put in place measures comprising:

• Contacting existing sub-contractors, and certain categories of land development consultants and professional legal advisers to ask them to confirm their adherence to our Anti-Slavery Policy.

• Ensuring that new core suppliers, sub-contractors, professional consultants and advisers undertake to comply with our Anti-Slavery Policy through use of due diligence questionnaires and relevant contractual provisions, with appropriate termination provisions for failure to comply.

• Ensuring that the high-risk areas as identified under paragraph 4.3 are kept under regular review to determine whether additional and/or targeted measures are required within our supply chain to combat the risk of slavery and trafficking.

• Ensuring that our whistleblowing procedure is drafted sufficiently widely to encourage whistleblowing in relation to any identified breaches of our Anti-Slavery Policy.

 

In 2024, we put in place some additional measures, comprising:

• Contacting any other categories of existing suppliers, consultants, and professional advisers as appropriate to ask them to confirm their adherence to our Anti-Slavery Policy.

• Suppliers and sub-contractors will be required, through their compliance with our Policy, to have in place their own due diligence practices and contractual obligations within their ongoing supply chain, with the aim of eliminating from their supply chain any suppliers or sub-sub-contractors who have trafficking or slavery practices within their supply chains.

• Give additional assurances if a sub-contract or supply contract relates to the high-risk areas identified in paragraph 4..

• Have in place their own whistleblowing procedure for identifying breaches of this Policy or the supplier or sub-contractor’s own policies.

• Have in place appropriate training on the requirements of the Act and relevant policies.

 

5. Communication and Awareness of the Policy

Training on this Policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work
for us, and regular training will be provided as necessary.

 

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.

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6. Disciplinary Processes and Supplier Adherence

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.

 

 7. Ongoing Review

This Anti-Slavery Policy will be subject to regular and ongoing reviews to ensure its effectiveness, and to update the requirements where further measures are identified.