Last Reviewed: 25/02/2026
Reviewed By: Pascal Brierley
Policy Statement
We Are RAM Construction Ltd is committed to conducting all business activities honestly, ethically and with integrity. We recognise our responsibility to prevent slavery, servitude, forced or compulsory labour, child labour and human trafficking within our business and supply chains.
We have a zero-tolerance approach to modern slavery and are committed to acting professionally, fairly and responsibly in all business dealings. We expect the same high standards from all contractors, subcontractors, suppliers, labour providers and other business partners.
This policy applies to all persons working for or on behalf of the Company in any capacity, including employees, directors, agency workers, labour-only subcontractors, consultants, suppliers and service providers.
This policy does not form part of any employee's contract of employment and may be amended from time to time.
1. Purpose
The purpose of this policy is to:
- Demonstrate the Company's commitment to preventing modern slavery and human trafficking.
- Ensure compliance with applicable legal obligations.
- Establish clear responsibilities for identifying and reporting concerns.
- Reduce the risk of exploitation within our business and supply chains.
- Promote ethical labour practices and respect for human rights.
- Provide guidance on reporting concerns and raising suspicions.
2. What is Modern Slavery?
Modern slavery is a term used to describe situations where an individual is exploited and unable to refuse or leave because of threats, intimidation, coercion, abuse of power, deception or financial control.
Modern slavery can take many forms, including:
Slavery
Ownership or control of a person as if they were property.
Forced or Compulsory Labour
Work or services extracted from a person under threat, coercion or penalty.
Human Trafficking
Arranging or facilitating the travel of individuals to exploit them.
Servitude
A person's freedom being significantly restricted, requiring them to live and work under coercive conditions.
Child Labour
The employment of children in work which is unlawful, exploitative or harmful to their health, wellbeing or development.
Examples of indicators may include:
- Workers appearing fearful or withdrawn.
- Individuals being controlled by another person.
- Lack of possession of identification documents.
- Excessive overtime without adequate pay.
- Poor living conditions.
- Workers being transported to and from work under suspicious arrangements.
- Restricted freedom of movement.
- Evidence of debt bondage or financial exploitation.
3. Responsibilities
Directors
The Directors have overall responsibility for ensuring this policy is implemented effectively and that adequate measures are in place to prevent modern slavery.
A Director will act as the Company's Anti-Slavery Officer ("ASO") and shall:
- Oversee compliance with this policy.
- Investigate reported concerns.
- Review supplier and subcontractor compliance where appropriate.
- Promote awareness throughout the business.
- Review this policy annually.
Managers and Supervisors
Managers and supervisors are responsible for:
- Leading by example.
- Ensuring employees understand this policy.
- Remaining alert to indications of modern slavery.
- Reporting concerns immediately.
- Supporting investigations where required.
Employees and Workers
All employees, contractors and workers must:
- Comply with this policy.
- Remain alert to modern slavery risks.
- Report concerns immediately.
- Cooperate with investigations.
- Avoid any activity that may breach this policy.
Failure to comply may result in disciplinary action, termination of contracts and, where appropriate, legal action.
4. Our Business and Supply Chains
We Are RAM Construction Ltd operates within the construction sector and provides construction, refurbishment, maintenance and associated building services.
Our supply chains may include:
- Construction subcontractors.
- Labour agencies.
- Temporary labour providers.
- Building material suppliers.
- Plant and equipment suppliers.
- Tool suppliers.
- Transport and logistics providers.
- Waste management companies.
- Professional consultants and service providers.
We recognise that the construction industry can present increased risks of labour exploitation due to the use of subcontracted labour and complex supply chains.
As a result, we are committed to ensuring that our business relationships are conducted responsibly and ethically.
5. Preventing Modern Slavery Within Our Business
The Company will take reasonable and proportionate steps to prevent modern slavery, including:
- Providing employees with clear terms of employment.
- Paying employees in accordance with applicable legislation.
- Complying with minimum wage requirements.
- Ensuring working hours, holidays and rest breaks comply with legal requirements.
- Verifying right-to-work documentation where required.
- Maintaining fair recruitment practices.
- Promoting a culture of dignity, respect and inclusion.
- Providing appropriate welfare facilities.
- Encouraging workers to raise concerns without fear of retaliation.
The Company will not knowingly employ anyone who has been trafficked, exploited or subjected to forced labour.
6. Supplier and Subcontractor Requirements
The Company expects suppliers, subcontractors and labour providers to share our commitment to preventing modern slavery.
Suppliers may be required to:
- Comply with applicable employment and human rights legislation.
- Confirm that modern slavery is not taking place within their business.
- Assess risks within their own supply chains.
- Provide evidence of compliance upon request.
- Cooperate with investigations where concerns arise.
- Implement corrective actions when required.
Where serious breaches are identified, the Company reserves the right to terminate contracts and cease trading relationships.
7. Due Diligence and Risk Management
The Company adopts a proportionate approach to due diligence.
Measures may include:
Recruitment Controls
- Verifying identity documentation.
- Checking right-to-work status where applicable.
- Using reputable recruitment agencies.
- Monitoring labour provider practices.
Supply Chain Controls
- Assessing new suppliers and subcontractors where appropriate.
- Reviewing supplier credentials and reputation.
- Seeking assurances regarding compliance with labour standards.
- Investigating concerns raised regarding suppliers.
Risk Assessment
The Company recognises that higher risks may exist in:
- Labour-only subcontracting.
- Temporary labour arrangements.
- Low-skilled labour supply chains.
- Suppliers with limited workforce transparency.
- Overseas manufacturing supply chains associated with construction materials.
Where risks are identified, appropriate action will be taken to reduce or manage them.
8. Reporting Concerns
All employees, contractors and workers have a responsibility to report suspected modern slavery.
Concerns should be reported immediately to the Company's Anti-Slavery Officer (A Director).
Reports may involve:
- Suspected human trafficking.
- Forced or compulsory labour.
- Child labour.
- Exploitation by subcontractors.
- Suspicious recruitment practices.
- Worker welfare concerns.
All reports will be treated seriously and investigated appropriately.
9. Protection for Whistleblowers
The Company encourages the reporting of genuine concerns.
No individual will suffer victimisation, disciplinary action, dismissal or any detrimental treatment for raising a genuine concern in good faith.
This protection applies even if an investigation concludes that no wrongdoing has occurred.
Deliberately false or malicious allegations may result in disciplinary action.
10. Investigation Procedure
Where concerns are raised, the Company will:
- Record relevant information.
- Conduct an appropriate investigation.
- Seek further information where necessary.
- Cooperate with relevant authorities where appropriate.
- Take suitable corrective action.
- Review existing controls to prevent recurrence.
Where criminal activity is suspected, the matter may be referred to the Police or other enforcement authorities.
11. Monitoring and Measuring Effectiveness
The Company will monitor the effectiveness of this policy through:
- Reports of modern slavery concerns.
- Supplier compliance reviews.
- Investigation outcomes.
- Recruitment monitoring.
- Feedback from employees and workers.
- Contract reviews where applicable.
- Internal management reviews.
The absence of reported incidents will not be taken as evidence that risks do not exist, and vigilance will be maintained at all times.
12. Training and Awareness
The Company is committed to raising awareness of modern slavery throughout the business.
Awareness may be delivered through:
- Employee inductions.
- Toolbox talks.
- Policy briefings.
- Management meetings.
- Health and safety meetings.
- Internal communications.
Training and awareness activities will help employees:
- Understand modern slavery risks.
- Recognise warning signs.
- Understand reporting procedures.
- Support ethical working practices.
13. Review
A Director shall be responsible for monitoring and reviewing this policy.
The policy will be reviewed annually or sooner if:
- Legislation changes.
- Significant organisational changes occur.
- New business activities are undertaken.
- Experience indicates improvements are required.