Anti-Slavery and Human Trafficking Statement 2020
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Modern Slavery Act 2015: Anti-Slavery and Human Trafficking Statement 2020 INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps taken by FCC Environment (UK) Limited and its subsidiaries; FCC PFI Holdings Limited, FCC Environment Services (UK) Limited and Telford & Wrekin Services Limited, together known as “FCC Environment” to prevent modern slavery and human trafficking in its business and supply chain. For a full list of company subsidiaries please see the attached 2021 company list. FCC Environment published its first Anti-Slavery Statement in November 2016. In this past year we have continued to increase our awareness of modern slavery by continuing our staff education programme and enhancing the education on our operational sites. Modern slavery is a crime and a 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 in order 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 seek 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. We expect the same high standards from all of 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 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. Slavery and human trafficking is a growing problem, and only by being vigilant as a company can we hope to try to tackle this. We understand that complicated supply chains pose the greatest risks for vulnerable workers and therefore this is where our greatest efforts have been and continue to be concentrated. ORGANISATION’S STRUCTURE FCC Environment is one of the UK’s leading waste and resource management companies providing a range of services from collecting business and municipal waste to recycling and processing and the generation of green energy from waste. We minimise the amount of waste that ends up in landfill by transforming it into valuable resources. FCC Environment is a key player within the municipal waste management sector, and we hold over 100 contracts with some 60 local authority clients across England, Wales and Scotland. We provide a diverse range of cost effective and sustainable waste processing, recycling, treatment, disposal and energy recovery services for local authority and private commercial customers. Annually, FCC Environment receives, treats, recycles and disposes of approaching 10 million tonnes of household, commercial and industrial waste and manages around 280 waste management facilities, and produces over 117MW of energy. Through innovative solutions, FCC Environment is committed to working with its local authority partners and industrial and commercial customers to respond to often complex and far- reaching waste management strategies, to meet the challenges of increased regulation, and to improve upon waste management targets. FCC Environment is a part of the FCC group, and our ultimate parent company is Fomento de Construcciones y Contratas, S.A. (“FCC”). FCC is a significant multi-national business with operations in Europe, South and Central America, Africa, the Middle East and the United States of America. FCC’s principal activities cover Environmental Services (including waste management), Construction, Cement and Infrastructure. The FCC group has accumulated 125 years of experience delivering services to citizens all over the world operating in 35 countries. OUR BUSINESS FCC Environment’s business in the UK comprises the following business activities: Recycling – comprising mechanical treatment plants, composting and household waste recycling centre, operations as well as several limestone quarries in Yorkshire; Green Energy – which manages EfW plants at Eastcroft in Nottingham (producing steam for the UK’s largest district heating scheme), at Allington in Kent, Greatmoor in Buckinghamshire and North Hykeham in Lincolnshire (producing electricity for export). In 2019 our new plant in Scotland entered into the services period of the contract delivering a waste solution for the Partner Councils the City of Edinburgh and Midlothian. The new plant has the capacity to accept 159,000 tonnes per annum comprising of up to 135,000 tonnes from the Partner Councils with the remainder secured through securing additional waste from other councils or the commercial market. The plant is exporting approximately 13 MW of electricity which is enough to provide power to 32,000 households and businesses. Waste Processing – comprising transfer station, landfill, hazardous waste treatment (including solid and liquid wastes) and clinical waste solutions; and Business Waste Solutions – which has UK responsibility for the collection of commercial and industrial and healthcare waste from FCC Environment’s business customers. This is to support the existing and planned infrastructure of the Recycling and Waste Processing activities. FCC Environment is committed to maintaining the highest ethical standards, and seek to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery policy reflects our commitments to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. OUR VALUES AND BEHAVIOUS At FCC Environment we have a vision for how we want our company to develop and grow and we want our company to be shaped by the values we hold and the people we work with, as we all work towards the same goal. This starts with how we treat our employees, our colleagues and our customers. Environmental Commitment; being environmentally and socially responsible in the services we provide Forward Thinking; embracing change and preparing for the future People Focus; valuing, rewarding and praising our teams, motivating others and enjoying the work we do Doing the Right Thing: building a successful and secure future by being customer focused and delivering quality services. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING We have undertaken due diligence checks of all suppliers in the form of ethical/compliance questionnaires and audits. We are committed to improving practices and we have in place systems to: Identify and assess potential risk areas in our supply chains. Mitigate the risk of slavery and human trafficking occurring in our supply chains. Monitor potential risk areas in our supply chains. Protect whistle blowers. SUPPLIER ADHERENCE TO OUR VALUES We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and our contractors comply with our values, ethics and policy, we have in place a supply chain compliance programme. All suppliers (new and existing) must confirm conformance to our Code of Conduct and policy or, alternatively, confirm that they have policies of their own with which they comply. TRAINING To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have provided awareness training to all our staff. All supervisors and managers are regularly trained to ensure they are aware of the signs of slavery and to advise them of the actions they should take should they suspect modern slavery exists. In 2020 a series of Toolbox Talks took place on all our sites, by the site managers. This refreshed the earlier training ensuring the message was clear staff aware on how to recognise modern slavery and what actions to take if recognised. OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains: - We understand that modern slavery risk is not static, and we will continue to seek to mitigate the risks in the years ahead. - We will assess the effectiveness of the measures being taken by monitoring, inter alia, staff training, supply chain audit and verification and investigations into reports of modern slavery. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes FCC Environment (UK) Limited’s anti-slavery and human trafficking statement. Paul Taylor Chief Executive Officer FCC Environment (UK) Limited Date: 19 March 2021 2021 Company List Company