Modern Slavery

Introduction

Thompsons is committed to driving out acts of modern-day slavery from within our business and supply chains.  We endeavour to improve our practices to combat slavery and human trafficking wherever possible.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out some background to our organisation and our supply chains.

Our Business and Supply Chains

Thompsons’s end-to-end services include construction and consolidation to fixture procurement and mechanical and electrical installation, as well as delivering bespoke client projects.  Thompsons has enabled the efficient and cost-effective delivery of thousands of new and refurbished environments worldwide.

Within our supply chain, there are relationships with external businesses for the sourcing of [sub-contractors, labour and supply partners] both nationally and internationally.  These, as well as the suppliers of services, make up the supply chains within the Company.

Our Policies on Slavery and Human Trafficking

Thompsons is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  This statement reflects our commitment 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.

Thompsons implements a number of policies and procedures which are designed to minimise the risk of modern slavery and human trafficking, both within our organisation and our supply chains.  We continue to review our policies to ensure that they remain effective and appropriate for the business.

• Anti-bribery and corruption policy – this policy helps create a culture where bribery is never acceptable and providing guidance to all staff to report and deal with the risks of fraud and corruption.
• Dignity at work policy – this policy sets out Thompsons’s commitment to providing a working environment free from harassment and bullying and helps to ensure that all of our staff are treated, and treat others, with dignity and respect.
• Health and safety policy – one of the key aims of this policy is to ensure the wellbeing of all our employees, contractors and anyone else who may be affected by our activities.
• Recruitment policy – we carry out appropriate checks to ensure that all of our staff have the requisite right to work documentation, that they are paid fairly and that they receive a competitive remuneration package for the work they undertake.
• Whistleblowing policy – this provides guidance on how to report suspected dangers or wrongdoing in the workplace.  All of our staff are expected to be alert to the risks, however small, in both our business and the wider supply chain.[RB1]

Supplier Adherence to Our Values

Thompsons expects all suppliers and any subcontractors engaged by the organisation to respect and conform to our fundamental values as conditions for mutual business.  Our standard terms and conditions require all of our suppliers to comply with the law.

We have a zero-tolerance approach to slavery and trafficking.  We have appointed a Head of Safety, Health Environment & Quality who will have overall responsibility for ensuring that all those in our supply chain and contractors comply with our values.

Risk Assessment

The Group will achieve our aims by our initiative to identify and mitigate risk in the following ways (this list is not exhaustive):

• Stringent vetting of our supply chain
• Continual audit and review of our practices for checking all employees are paid at least the minimum wage and have the right to work
• We encourage the reporting of concerns and protection of whistle blowers
• The Group will not knowingly support or deal with any business involved in slavery or human trafficking
• We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values

To ensure understanding of these risks within our supply chain and our business we provide training to relevant members of staff. All directors have been briefed on the subject.

Due Diligence Processes

Thompsons will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chains:

• Completion of audits by Directors, Managers and Safety, Health, Environment and Quality Managers
• Labour monitoring and payroll systems
• Level of communication and personal contact with next link in the supply chain, including their understanding of and compliance with our expectations