Built Developments Ltd. is committed to conducting business ethically and in a way that protects the freedom and dignity of all people. We have zero tolerance for any form of modern slavery, including human trafficking, forced or compulsory labor, child labor, and abuses of workers’ rights. This policy applies to all employees, workers, and temporary staff, and to all business operations and supply chains.
Scope – Applies to Built Developments Ltd, its subsidiaries, and all project sites, offices, and subcontractors. – Covers all workers including direct employees, agency staff, subcontractors, and migrant workers. – Extends to all procurement, recruitment, and outsourcing activities.
Key principles – Respect for human rights: comply with applicable laws and international standards on labor rights. – Employee wellbeing: ensure safe, healthy, and fair working conditions. – Transparency: maintain visibility across the supply chain and adjacent services. – Accountability: clear owner responsibility and prompt remedial action for violations.
Responsibilities – Board/Executive Owner: endorses policy, approves resources, and reviews annual progress. – Policy Owner (HR Director/Operations Director): maintains policy, leads risk assessments, oversight of training, and supplier due diligence. – Site Managers and Supervisors: implement policy on site, monitor working conditions, and escalate concerns. – Procurement/Supply Chain: assess supplier risk, perform due diligence, and ensure contracts require compliance. – All Employees and Contractors: comply with policy, report concerns, and cooperate with investigations.
Risk assessment and due diligence – Conduct annual risk assessment focused on supply chain, recruitment practices, sub-contractors, and migrant labor patterns in construction operations. – Identify high-risk sites, regions, and supplier categories; implement mitigating controls. Require suppliers to certify compliance with modern slavery standards and provide evidence on demand.
Recruitment and employment practices – Prohibit illegal and exploitative recruitment practices, including debt bondage, confiscation of identity documents (where legally restricted), and withholding wages. – Use transparent, traceable recruitment channels; ensure fair recruitment fees paid by employers or properly documented where fees are allowed by law. – Ensure employment contracts are clear, in a language workers understand, and include accurate terms (hours, rate, breaks, overtime, accommodation if provided). – Monitor payroll to ensure workers are paid at or above legal minimum wage and in a timely manner.
Migrant workers and accommodation – Provide safe, legal, and voluntary accommodation where provided; ensure conditions meet health, safety, and basic living standards. – Ensure workers understand their rights and can access grievance channels without fear of retaliation.
Training and awareness – Provide regular anti-slavery and human trafficking training for all staff, with enhanced training for procurement, site management, HR, and onboarding teams. – Communicate policy expectations and reporting procedures clearly across the organisation.
Whistleblowing and reporting – Maintain confidential, accessible reporting channels (hotline, email, or in-person) for concerns about modern slavery. – Protect whistleblowers from retaliation; investigate all reports promptly, fairly, and confidentially. – Take appropriate corrective actions, including remediation for victims and disciplinary action for individuals found responsible.
Remediation and supplier corrective actions – In cases of confirmed modern slavery issues, halt or reassign work with offending suppliers or contractors. – Require immediate remedial action from suppliers (e.g., fair payment, safe conditions, access to remedy for affected workers). – Support victims with access to appropriate services and ensure they are not disadvantaged in employment as a result of reporting.
Supply chain management – Include modern slavery provisions in supplier codes of conduct and contracts. – Require suppliers to maintain policies and records demonstrating compliance (audits, risk assessments, worker interviews where appropriate and legally permissible). – Perform supplier risk-based audits and, where feasible, third-party due diligence.
Monitoring, review, and continuous improvement – Track key metrics (e.g., supplier compliance rates, corrective actions completed, training completion, number of concerns raised and resolved). – Review policy effectiveness annually and after any incident; update procedures and controls as needed. – Report progress to senior leadership and, where required, to regulators or stakeholders.
Compliance – Comply with applicable national and international laws relating to modern slavery and labor rights. – Maintain records of risk assessments, training, supplier due diligence, and remediation actions for audit purposes.
Documentation and access – This policy is publicly available on the company website and internally distributed to employees, contractors, and suppliers. – All staff are informed of their rights and reporting processes through onboarding and ongoing communications.
Date of issue: 2nd February 2026
Policy owner: Jay Culbert
Review date: 2nd February 2027
