Modern Slavery and Human Trafficking Compliance Statement

  1. INTRODUCTION

At Modulaire Group (“Modulaire”), we operate our business in a responsible manner and to the highest standards of business conduct in order to ensure compliance with all applicable laws and regulations. As such, we are committed to constantly improving our practices across our business and taking positive steps to ensure that slavery and human trafficking do not take place in our supply chains or our business.

We acknowledge that slavery can occur in many forms, including human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, child labour, and deceptive recruiting. Whilst we have already taken steps to comply with the legal requirements to combat the various forms of modern slavery, we continue to work with our suppliers and employees to ensure that modern slavery does not occur within our supply chains or our business.

We have assessed our suppliers’ Environmental, Social, Governance & Sustainability (ESGS) performance, including modern slavery issues and are continuing to develop systems and actions to screen and assess our suppliers’ ESGS and modern slavery risks regularly. Therefore, this statement presents the actions already taken and our continuous plans to address modern slavery in our operations and supply chains.

  1. OUR STRUCTURE AND SUPPLY CHAINS

Our Business

Modulaire provides services and infrastructure. Modulaire’s core product offering provides customers with flexible, cost-effective, high-quality, and timely solutions to meet their space and remote accommodation needs. In addition to modular space units, the business also provides complimentary services such as heating and air conditioning, catering, security and fire protection, facility management, furniture, and IT solutions.

Modulaire operates across 23 countries in Europe and Asia Pacific. The company operates as Algeco, its largest brand, across much of Europe and the United Kingdom. Other operating brands include Advanté in the United Kingdom, Altempo in France, Algeco Chengdong in China, Ausco and NET Modular in Australia, and Portacom in New Zealand. All our subsidiaries operate with common board members, corporate functions, policies, and procedures. Further details about us can be found at www.modulairegroup.com.

Supply chains

Depending on the products or services, we engage with our suppliers through different forms, such as one-off purchases or long-term supply contracts. In 2023, we partnered with approximately 20,000 suppliers, of which 3,000 represent 90% of our spend (Key Tier-1 Suppliers).

Based on our supply chain profile, the risk of modern slavery in direct suppliers remains relatively low. From a geographic perspective, 1.4% of our Key Tier-1 Suppliers are based in countries deemed high risk, including Romania, Hungary, China, Croatia and Turkey. We recognise that the risk of modern slavery may increase further down our supply chain (Tiers 2 and below), where we have lower visibility and generally lower ability to influence.

The majority of our vendors and subcontractors broadly cover the following categories of goods and services:

  • Materials for buildings, including steel components, walls and panels, insulation, electrical components, plumbing supplies and flooring; and
  • Sub-contract services for construction, catering and housekeeping, specific delivery, installation, disassembly and repair/maintenance work.

Relationships with Trade Unions and other bodies representing workers

We have trade unions and work councils in place (in certain countries) that are managed at a local level by our leadership teams. The scope of agreements and discussions is primarily in place to discuss and negotiate the terms and conditions of our people (i.e. pay), local legislation, and working practices that need to be followed.   

We maintain positive relationships and regularly engage through forums to share our business performance and colleague expectations and to communicate policies. This enables us to gather feedback on our performance and practices and collaborate to inform and consult on embedding local changes when required. 

  1. POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING

We are fully committed to ensuring there is no modern slavery or human trafficking in our supply chains or any part of our business. We further that commitment by implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking do not occur at any level of our business and supply chains.

We have a robust governance framework to monitor and mitigate modern slavery risk. Our governance underpins how we conduct our business and interact with suppliers:

  • Our Quality Management System (ISO 9001 certified) consists of policies and procedures related to human resources, health and safety and supplier management.
  • Our Supplier Code of Conduct, ESG & Sustainability Policy, and Code of Ethics reflect our commitment to acting ethically and with integrity in all business relationships.
  • We nurture a transparent culture where anyone can raise concerns about our business without fearing retaliation. Our Speak-Up policy outlines how reports can be made and whistle-blower protections.
  • We are implementing our Responsible Sourcing Policy, which outlines our requirements and procedures to collaborate with suppliers along the supply chains, embed ESGS at all stages, review ESGS performance as part of routine supplier relationships, improve our knowledge of the supply chains upon which we depend and drive continuous ESGS improvements.  
  • To ensure that all those in our supply chains and our contractors comply with our values, we will require vendors to adhere to our Supplier Code of Conduct and standards, including a commitment not to use slave labour or participate in human trafficking. We seek acknowledgement of adherence at the stage of onboarding our suppliers.

Our Group’s respective business functions develop our policies in collaboration and consultation with relevant teams across the business at both Group and subsidiary levels.

  1. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

Our focus for 2024 is the roll-out of our Responsible Sourcing Policy, screening suppliers with our new assessment process and training the procurement team. We will request our direct suppliers to cascade human rights and modern slavery standards down the supplier’s own supply chains.

Supplier Assessment and Screening

Our framework of policies, processes and programmes is in place to identify and reduce potential human rights impacts, including modern slavery and human trafficking. We are committed to improving our supplier governance framework to enhance visibility throughout the supply chain.

Under the Responsible Sourcing Policy our approach to suppliers’ (modern slavery) assessment and screening is based on the following risk factors: high-risk geographies, high-risk sectors, and vulnerable populations. Supplier assessment and screening consist of three options depending on the situation and requirements.

  • Assessment Level 1 – rapid screening and classification of supplier ESG performance and associated risks.
  • Assessment Level 2 - detailed questionnaire for assessing and classifying supplier ESG performance and associated risks.
  • Assessment Level 3 - in-depth due diligence on an individual supplier. This in-depth questionnaire comprises questions on environmental, social and governance considerations for the assurance of single products from high-risk sectors or geographies.

Management of the process

  • All team members who directly engage with suppliers in any of our locations will be trained to be familiar with our Responsible Sourcing Policy.
  • We will typically prioritise high-spend suppliers or supply chains which are inherently high-risk by their geography or sector.
  • We will commence with Key Tier-1 Suppliers and suppliers in higher-risk geographies. Before service engagement, all newly engaged vendors will be subject to thorough review and adherence to our standards.
  • If suppliers do not conform to our screening and improvement process, they ultimately should not be used.
  1. RISK ASSESSMENT AND MANAGEMENT

Direct business operation:

Within our direct business operation, we consider the risk of modern slavery to be low. We monitor and mitigate this risk through our existing governance and systems. We fully comply with the relevant national labour legislations where our subsidiaries are. We have policies and procedures relating to staff employment and their onboarding, including our approach to modern slavery and intolerance of any form of bullying or discrimination.

Supply chain

From a geographic perspective, our supply chain data suggests that 98.6% of our Key Tier-1 Suppliers are based in low-risk countries, and 1.4% are in high-risk countries.

We recognise that we may be exposed to modern slavery risks, directly or indirectly, especially beyond our direct suppliers, where we have no direct influence. We have therefore conducted an ESGS assessment of our key suppliers and the data collected has helped us to map potential hotspots of modern slavery across our supply chains concerning geographic locations, business sizes, goods and services.

Actions taken to address and assess modern slavery risks

To address and assess the risks of modern slavery in our business, Modulaire has undertaken the following actions across our subsidiaries:

  • Conducted an ESGS assessment of our Key Tier-1 suppliers, which covers modern slavery issues.
  • Assigned responsibility for monitoring and addressing modern slavery risks to senior managers.
  • Set up a mechanism to allow people to safely report modern slavery risks in our business operations and supply chains through our Speak-up Policy.
  • Developed a Responsible Sourcing Policy, which outlines specific actions for our people in assessing and screening our suppliers’ ESGS performance (modern slavery included).
  1. PERFORMANCE INDICATORS

We have KPIs to measure the effectiveness of our practices in addressing modern slavery within our business operations and across our supply chains.

In addition, we align our approach to sourcing with principles from international development organisations, such as:

  • The International Labour Organization’s (ILO) Fundamental Principles and Rights at Work. These principles cover core workers’ rights such as freedom of association, the elimination of forced labour, and no discrimination.
  • The United Nations Guiding Principles for Business and Human Rights (UNGPs). These provide a framework for the measures nations and businesses should implement to protect and respect human rights.
  • United National Global Compact (UNGC). We have been a signatory to the UNGC since 2021 and are updating our policies and practices to reflect their ten principles (https://www.unglobalcompact.org/what-is-gc/participants/144802-Modulaire-Group). The assessment framework and reporting/communications mechanism of UNGC also help us assess the effectiveness of our measures in addressing modern slavery. We report annually on our progress in sustainable corporate governance against the ten Principles through a Communication on Progress report.

 (https://www.unglobalcompact.org/participation/report/cop/create-and-submit/advanced/465298)

  1. TRAINING

All our operating countries adhere to our standards and expectations for modern slavery commitment. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to our staff with direct responsibility for our supply chain and will continue to provide this training to relevant new employees in our organization.

  1. PROCESS OF CONSULTATION

We have brought this statement to the attention of those in our Group Procurement team, ESG & Sustainability team, HR team, and respective functions of our subsidiaries and given them the opportunity to provide feedback, raise queries and have such queries answered. We have also involved our Legal and Procurement teams in further assessing the risk of non-compliance in our supply chains. 

  1. OTHERS

Fully aware of the importance of businesses in combating modern slavery, Modulaire and our subsidiaries actively present our work at international and local forums to raise awareness of the issue. We also constantly learn from other organisations and quickly employ best practices to improve our actions on the topic.

10. ENDORSEMENT OF THIS STATEMENT

This statement was approved by the Board of Modulaire and its subsidiaries.

 

James Odom
Group General Counsel
Modulaire Group

Last updated 4 January 2024