Modern Slavery.

Revision 2 (December 2021) – last reviewed 29 March 2022. Download this statement as a PDF.

Business structure and supply chain

MSF is a UK based street furniture technology and lighting company that was established in 2011. We are committed to upholding our company values.

We strongly believe in our company values and the professionality they convey in the modern diverse workplace. We believe in transparency and an empowered workforce that collaborates in an innovative way with all our partners to ensure excellence and safety in everything we do. These values are the pillars that we build upon to ensure we are doing our best to be an ethical corporate citizen. We currently do not fall within the reporting parameters within section 54 of the Modern Slavery Act 2015. Therefore, this statement will explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This document is intended to fulfil the legal requirement for a slavery and human trafficking statement for the company. Our efforts against slavery and human trafficking complement our broader CSR policy and ethical trading.

MSF is based in Podington, Northamptonshire with two other operating depots in Newton Aycliffe and Dartford. Our service utilises products from UK based low risk companies that are governed by set materials standards to be used on UK Highways (Manual of Contract Documents for Highway Works Contents). We have under 250 employees within our organisation with under 1000 approximately who are engaged through our supply chain.

We are currently not required to publish an annual slavery and human trafficking statement but feel it is in our interests to have this statement published for the betterment of the wider business CSR commitments and to share our efforts in doing this.

Slavery and human trafficking policies

Modern slavery is a term which is used to encompass slavery, forced and compulsory labour and human trafficking. It applies equally to adults and children, when they are forced to work against their will and often for little pay or no pay or other basic workers’ rights.

The Modern Slavery Act 2015 placed a duty on commercial organisations supplying goods and services and who operate within the United Kingdom, to ensure that their operations and supply chains are free from acts of modern slavery and human trafficking.

We have developed this policy to demonstrate our commitment to the prevention of slavery and human trafficking and we are updating our supplier code of conduct to reflect this.

We have set clear goals for this year and will be setting further 1-, 3-, and 5-year objectives based on current and potential risk as the company grows. We are basing our objectives on the following themes:

Relationships – strengthening our supplier onboarding and engagement process.
Feedback – strengthening and educating our mechanisms for individual worker feedback and whistleblowing policies.
Knowledge – improving our knowledge of employee and supplier issues by collecting relevant data and improving product traceability.
Third party engagement – working with current and future auditors and building relationships with auditors and clients.
Measuring change – developing KPI metrics to measure our progress.
Collaboration – working with suppliers to collaborate on slavery and human trafficking issues.
Accountability – establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking.

Due diligence

MSF Ltd understand that our biggest risk of exposure to modern day slavery and human trafficking is with our supply chain. We ourselves have performed a modern slavery risk assessment and as a company that self-delivers 99% of our workload are comfortable that we present a low risk throughout our supply chain.

This means that we will incorporate into our due diligence, any appropriate measures to ensure that anyone we enter business with do not engage in acts that could fall within the definition of modern slavery and that we protect the reputation of ourselves and our clients as fair and reasonable employers. To do this we regularly, through our onboarding process, perform due diligence that our supply chain is performing their due diligence throughout their own supply chain.

Our supply chain all fall within the UK borders and are considered low risk.

Ethical employment

The company upholds the principle of “ethical employment” in the running of our business and the work we do. We will ensure that:

We act with integrity and transparency.
We provide a safe working environment.
We promote health and wellbeing amongst employees and workers.
Employment is freely chosen.
Children and young workers are not exploited.
Working hours for employees are not excessive.
Employees are properly remunerated for the work they do.
Appropriate training is provided to ensure employees can perform their job.
No individual will suffer discrimination, harassment, or victimisation of any kind.
We will work with employees to resolve any grievances or disputes.

As a legislative compliant company, we expect our supply chain to act in a similar manner and to provide assurance that they uphold similar principles, and we uphold the right to withdraw from agreements where no evidence is forthcoming.

Identifying, assessing and managing risk

Within our scope of business, we set out to identify the extent of any human trafficking with our supply chain by:

Documented supply chain onboarding reviewed biannually and vetting using SSiP companies.
Random spot checks and audits on our supply chain working on our behalf.
Random audits of our direct supply chain management systems.
Reviewing supplier slavery and human trafficking policies and training.

Key performance indicators

In order to assess the effectiveness of our modern-day slavery measures we will be reviewing the following key performance indicators:

Staff training levels.
Any slavery incidents reported within the supply chain.
Right to work check discrepancies.
Audits carried out on the supply chain, both on site and in office.

Training available to staff

A key part of our slavery and human trafficking strategy is to promote cultural change through training. This financial year we will:

Make this policy available and ensure it is included within all staff inductions.
Deliver an online training module to all staff making them aware of the issue of modern slavery.

Employees’ right to work in the UK

All employees are vetted for nationality on the application and induction process; anyone working for or onboarding with the company must have been checked for their right to work in the UK.

The company uses the Home Office right to work checklist as described in the Home Office Right to Work Checks supporting guidance, ensuring we comply with the Immigration, Asylum & Nationality Act 2006. There are two types of right to work checks: a manual document-based check and an online check. Conducting either check as set out in the guidance and in the code of practice provides a statutory excuse. We use the Employer Checking Service where an individual has an outstanding application, administrative review or appeal, or if their immigration status requires verification by the Home Office.

Manual document-based checks follow the three prescribed steps – obtain original documents from the acceptable lists, check they are genuine, belong to the holder and permit the work offered, and copy and securely retain them for the duration of employment and at least two years afterwards. Full step-by-step detail is set out in the PDF version of this statement.

Review

This policy will be reviewed annually as a minimum requirement, or in the event of any significant change.

Director and Responsible Manager: Shaun Stacey