Modern Slavery Act Transparency Statement

Overview
In accordance with the UK Modern Slavery Act 2015 (section 54 (1)), this Modern Slavery Transparency Act statement is made on behalf of Linbrooke Services Ltd and all its subsidiaries for the financial year ending 31 March 2021. The statement sets out the steps we have taken to prevent modern slavery and human trafficking happening in both our business and supply chain.
Linbrooke Services Ltd conducts our business fairly, ethically and with respect to fundamental human rights. We are committed to the prevention of all forms of modern slavery, both in our business and in our supply chains. We will not tolerate it.

Our Anti-Slavery Officer (‘ASO’) is Simon Noble, Group Finance Director. They are responsible for this policy.

How our Organisation is Structured

Linbrooke Services Ltd are a leading provider of mission-critical solutions in telecoms, power and signalling – predominantly in Rail, Utilities and Subsea environments. Linbrooke Services has over 345 employees across 5 regional offices in the UK.

As a Principal Contractor (PC) for Network Rail and an Independent Connection Provider (ICP) with National Electricity Registration Scheme (NERS) accreditation, we have world-class multifunctional in-house design and build capability. This enables us to provide a comprehensive service, from design, installation, test, commissioning and integration through to training and resourcing, ensuring exceptional time and cost savings on all our projects.

Preventing Modern Slavery in our Business

We acknowledge that modern slavery could possibly take place within our workforce but also within our supply chain. We carry out appropriate checks on all employees including right to work checks. We have a stringent onboarding process for our supply chain partners including regular meetings audits, so that we know who is working for us, or on our behalf.

We give every employee a written employment contract, and all are is paid in accordance with the law. We comply with our legal obligations to ensure the health and safety of all our employees and workers, including in relation to working hours, rest breaks and holidays.

We work in partnership with a broad range of national and international suppliers and therefore see this as our primary focus for managing and monitoring any potential contravention of the legislation.

These organisations are all subject to our strict control measures as we continually address our concerns regarding modern slavery in our supply chain. We have a preferred suppliers list and will only trade with partners and suppliers who, through our process of due diligence and audit at the bid and tender stage, can comfortably demonstrate their compliance and commitment to the Modern Slavery Act 2015.

Due Diligence – Suppliers

Linbrooke Services Ltd are proud to hold elite CHAS status; gold membership of Constructionline – inclusive of their ‘Social Value’ certificate and are members of the BSI and RISQS. In addition to our own internal risk assessments and vetting of our suppliers, we complement this with our accredited partners pre-qualification processes.
As part of our Subcontractor Approval Process any potential supplier of goods or services must assess their business and supply chains and confirm to our ASO that they:

• comply with their legal obligations, in relation to Modern Slavery; and
• are committed to ensuring there is no Modern Slavery taking place in their business, or in any of their supply chains.

Compliance audits are completed monthly by the Group Compliance Manager against our subcontractor and supplier requirements. Where a non-compliance is found, we will take appropriate action with the relevant supplier.

Policies and Training
We recognise that every colleague of Linbrooke Services Ltd has a responsibility towards identifying potential human trafficking and modern slavery within our business and supply chain. We therefore have mandatory online training for all colleagues in respect of this. This training is completed upon employment and refreshed annually.

We also provide colleagues with a library of policies and procedures to enable us to operate fairly, ethically and with respect to fundamental human rights. These policies include our Recruitment, Equality Diversity & Inclusion, Whistleblowing and Harassment and Bullying policies. Linbrooke Services Ltd also hold a Confidential Incident Reporting and Analysis System (CIRAS) certificate which provides colleagues with further access to Whistleblowing and support.

We hold all our employees to the highest standards of ethical practices and require our supply chain to adhere to the same standards. Remedial action will be taken either internally or externally, as required, should these standards not be met.

Date: October 2022