Modern Slavery
Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Clarke Lambert Construction Ltd has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

Clarke Lambert Construction Ltd has a zero-tolerance approach to modern slavery. 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.

Clarke Lambert Construction Ltd (trading as Clarke Lambert Construction) is a multi-trade construction contractor based in Kettleshulme, Cheshire, operating across education, healthcare, and commercial sectors. We have been trading since 1991 and engage a supply chain of subcontractors and suppliers across the North West of England.

We recognise the construction industry as a sector with elevated risks of labour exploitation. Regardless of our turnover threshold, we voluntarily publish this statement as part of our commitment to ethical business practices. This recognition drives our proactive approach to identifying and mitigating these risks.

Our supply chain principally comprises subcontractors providing specialist construction services, material suppliers, plant hire companies, and professional service providers. We maintain a vetted and approved supply chain database, and all subcontractors are required to undergo a pre-qualification process before engagement.

We recognise that the following areas of our supply chain carry higher risk:

• Labour-intensive trades such as groundworks, demolition, and general labouring where agency labour may be used.
• Material supply chains that extend internationally, particularly for manufactured goods and raw materials.
• Cleaning, security, and facilities management services provided by third parties on our construction sites.

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner. These include:

• Modern Slavery Policy: establishes our zero-tolerance position and sets out the responsibilities of all employees and subcontractors in observing and upholding our position.
• Whistleblowing Policy: encourages all workers, including agency staff and subcontractors, to report concerns about any aspect of our business, including suspected modern slavery, without fear of retaliation.
• Ethical Procurement Policy: sets out the standards we expect from our supply chain, including compliance with all applicable laws regarding modern slavery and human trafficking.
• Recruitment Policy: includes robust checks on the right to work in the UK for all directly employed staff, and requires our recruitment partners to demonstrate equivalent safeguards.
• Subcontractor Code of Conduct: requires all subcontractors to confirm their compliance with the Modern Slavery Act 2015 and to cascade equivalent requirements through their own supply chains.

As part of our initiative to identify and mitigate risk, we have implemented the following due diligence procedures:

• Pre-qualification assessments for all new subcontractors, which include specific questions on modern slavery policies, procedures, and compliance history.
• Regular audits of high-risk subcontractors, including unannounced site visits to verify working conditions, accommodation arrangements, and payment practices.
• Verification of right-to-work documentation for all workers on our sites, including those employed by subcontractors.
• Monitoring of payment practices throughout our supply chain to identify any indicators of labour exploitation, such as excessive deductions or withholding of wages.
• Review of agency labour providers to ensure they are licensed by the Gangmasters and Labour Abuse Authority (GLAA) where required.

We conduct an annual risk assessment of our business and supply chain to identify areas where modern slavery risks are most likely to occur. Our assessment considers factors including the nature of the work, the geographical location, the use of agency or temporary labour, and the length and complexity of supply chains.

For the current reporting period, we have identified the following key risk areas and corresponding mitigation measures:

We provide training on modern slavery awareness to all employees as part of their induction, with refresher training delivered annually. Additional targeted training is provided to staff in procurement, site management, and human resources roles, as these functions are most likely to encounter indicators of modern slavery.

Our training programme covers the following areas:

• Understanding what modern slavery is and how it manifests in the construction industry.
• Recognising the signs and indicators of modern slavery and labour exploitation.
• Understanding the legal framework, including the Modern Slavery Act 2015 and the responsibilities it places on businesses.
• How to report concerns through our internal whistleblowing procedure and to external bodies such as the Modern Slavery Helpline (08000 121 700).

We measure the effectiveness of our steps to ensure that modern slavery is not taking place in our business or supply chain through the following indicators:

• 100% of new subcontractors completing the modern slavery pre-qualification assessment before engagement.
• Completion of annual modern slavery training by all directly employed staff.
• Number of site audits conducted specifically addressing labour practices and working conditions.
• Number of concerns raised through our whistleblowing procedure relating to modern slavery.
• Number of subcontractors removed from our approved list due to non-compliance with our modern slavery requirements.

We are committed to continuous improvement in our monitoring and reporting of these indicators.

We encourage anyone who has concerns about modern slavery in any part of our business or supply chain to report them. Concerns can be raised through the following channels: