Modern Slavery Act Transparency Statement

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Barhale Holdings plc is the parent company of Barhale Ltd, Barhale Construction Services Ltd (BCS Group), Fleming & Company (Machinery) Limited and Barhale Properties Ltd. Barhale Ltd is a large civil engineering contractor directly employing approximately 900 staff in regional offices and projects across the United Kingdom. We do not currently operate outside of this geographical areas. BCS Group is a supplier of safety and construction products and services in addition to sign production, steel fabrication and plant. Barhale Properties Ltd holds and manages Barhale’s property portfolio.

 

The main sections that Barhale work in are water, energy, transport and built environment. Within these sectors, our business activities include civil engineering, tunnelling, MEICA, steel fabrication, plant, training, and the provision of signs and supplies.

 

The Barhale preferred delivery structure is to self-deliver, with an aim to utilise our supply chain for specialist skills and peaks in workload.

 

Our immediate Tier One supply chain is focussed on the activities of:

a) Procurement of construction materials
b) Hiring and provision of plant and machinery
c) Sourcing subcontracted labour services to support and augment our existing resources.

 

98% of our materials are purchased directly with UK based suppliers, distributors or agents. These suppliers, distributors or agents may use international Tier Two manufacturers.

 

The primary focus of implementing a Modern Slavery and Human Trafficking Statement across Barhale is to ensure that anti-slavery activity is recognised and embedded within our business as standard practice. We endeavour to ensure that all staff members, regardless of position, take joint responsibility for the identification and reporting of issues, to ensure basic standards are clearly communicated and met.

 

The following is a list of steps we have taken to ensure no Modern Slavery or Human Trafficking exists within our own business or any of our supply chains;

 

1. Amendments to existing Barhale Corporate Social Responsibility Statement, stating nonacceptance of Modern Slavery and Human Trafficking in any form and adherence to the 2015 Modern Slavery Act.

2. Distribution of the Modern Slavery Statement and supporting information to existing workforce,
suppliers, subcontractors and labour providers. Publication of the Barhale Modern Slavery
Statement on all Barhale company websites and within all relevant published media.

3. Changes to the structure of our supply chain pre-qualification questionnaire and processes, requesting that all potential suppliers adhere to the ethics detailed in the Barhale Corporate Social Responsibility statement and behaviours detailed therein. Signed Acceptance is required.

Additionally we work in conjunction with Constructionline and Achilles supplier prequalification
systems which address the issues of Modern Slavery and Human Trafficking within their
integral audit acceptance processes.

4. Barhale operates and trades in accordance with the Base Code Principles as laid out in the
Ethical Trade Initiative.

5. Ongoing programme of procurement team training on Ethical Procurement and Supply, in conjunction with the Chartered Institute of Purchasing and Supply, to instil practises of issue identification, reporting methods, issue management and improvement. This staged process will ensure due diligence and transparency of action at all stages.

6. Promotion of contact details and awareness of Modern Slavery issues, across our business
and supply chains, for individuals to obtain guidance and support, including but not limited to,
Barhale Whistleblowing Helpline, UK Government Modern Slavery Helpline, Slavery and
Human Trafficking helplines for both male and females, and website resources for definitions,
identification and practical assistance.

7. Distribution of our regularly updated Modern Slavery Statement across our business and
supply chain partners.

8. Ongoing development of KPI, reporting and auditing measures to ensure continual progress,
developed in conjunction with Barhale supply chain.

9. Delivery of Modern Slavery training within our Corporate Induction presentation to all new
members of staff, featuring guidance on identification and methods of reporting suspected
instances.

10. These measures are subject to ongoing review and additional measures will be developed and
implemented as required, and reviewed as a minimum on an annual basis, within six months of
the financial year end, which for Barhale is the end of June.

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Matthew Behan

Chief Executive Officer

May 2019