Modern Slavery Statement
1 - Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes numerous forms including whilst not being limited to slavery, forced servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of person’s liberty by another for the purposes of exploitation for personal or commercial gain.
NRT Group (“the Company”) has a zero tolerance approach to modern slavery and we aim to protect the human rights of all our employees and those within our supply chain. We are committed to acting ethically and with integrity in all our dealings and relationships in accordance with the Modern Slavery Act 2015. We implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within the Company or within any third parties with which we are associated. In addition to the requirements of the Modern Slavery Act 2015, we endorse the principles of the United Nations Global Compact Principles, the International Labour Organisation Declaration on Fundamental Principles and the Rights at Work and the Ethical Trading Initiative ‘Base Code’.
We are committed to transparency in our organisation and that our approach to tackling modern slavery is consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same standards from our sub-contractors, supply chain and other business partners.
This statement defines the steps taken by NRT Group in the financial year ending 31 July 2023 to prevent modern slavery and human trafficking in our operations and those of and is published in accordance with Section 54 of the Modern Slavery Act 2015.
2 – Our company
Registered as a private limited company with Companies House since 25 July 1996, NRT Group is a specialist NICEIC-accredited electrical contractor operating from a head office at Castle House, Park Road, Banstead, Surrey. Our turnover in the financial year ending 31 July 2023 was £16,919,269. We are commissioned by buyers in London and the South East to undertake electrical works in commercial and domestic contexts, with our specialisms including programmes of EICRs, electrical upgrades and rewiring, electrical installations, electrical maintenance and repairs including code fault rectifications, lateral and rising mains replacement and upgrades, emergency and communal lighting and active fire safety systems. Our NRT Eco division provides buyers and customers with a range of renewable energy solutions including solar PV, EV chargers, battery storage systems and energy assessment services.
3 – Our governance in relation to Modern Slavery
We have a long-established approach to the development, implementation and review of company policies. We review our Modern Slavery and Human Trafficking policy on an annual basis and our policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, agency workers and volunteers. Our policy does not form part of our employees’ contract of employment and may be amended at any time. Other NRT policies relevant to protecting human rights and minimising the risk of modern slavery and human trafficking include:
- Our Procurement policy
- Our Recruitment and Selection policy
- Our Code of Conduct
- Our Whistleblowing policy
4 – Responsibility for our policy
NRT’s Management Board has overall responsibility for ensuring that our Modern Slavery and Human Trafficking policy complies with our ethical obligations and all related UK legislation. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy, and a briefing is provided as part of all new starters’ induction programmes.
5 – Compliance with our policy
All those working with for or on behalf of the Company must ensure that they read, understand and comply with our policy, including changes made as a result of policy review or legislative changes.
The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us. Our employees are required to avoid any activity that might lead to, or suggest, a breach of our policy.
If employees believe or suspect that a breach of our policy has occurred, is occurring or may occur, they must notify their manager or report it in accordance with our Whistleblowing Policy at the earliest possible instance. The matter will be referred onto our Managing Director who will investigate the reported breach in conjunction with the necessary agencies or third parties.
We encourage openness and will support anyone who reports concerns in good faith, even if they turn out to be mistaken. We ensure that no-one suffers any detrimental treatment as a result of reporting a suspicion that modern slavery in any form is or may be taking place in any part of the Company or our network of wholesalers and sub-contractors.
6 – Recruitment and selection
NRT Group is committed to responsible recruitment. We advertise our vacancies in physical and digital contexts and, as applicable, use established, reputable employment agencies and consultants to source candidates for our vacancies. In the latter instance, we carry out checks of their policies and procedures to ensure that recruitment is undertaken in accordance with good practice and relevant UK legislation including the Modern Slavery Act 2015.
We always undertake checks of ID documents and evidence of selected candidates’ legal right to work in the UK before offers of employment are made. We also request written references and, where applicable, Enhanced DBS checks.
7 – Suppliers, Sub-Contractors and Third Parties
We expect our suppliers and other business partners to have the same high standards as we impose on our own business. NRT Group draws upon the resources of a wide network of electrical wholesalers and specialist sub-contractors to meet our contractual obligations with our buyers. Our standard terms and conditions require our suppliers and sub-contractors to comply with all relevant UK legislation, including the Modern Slavery Act 2015.
In accordance with our annually reviewed Procurement policy, we undertake due diligence procedures when considering sourcing stock from new suppliers or procuring the services of sub-contractors, reviewing their Modern Slavery and Human Trafficking policies and statements before procuring their services to ensure their adherence to UK anti-slavery and human trafficking legislation.
8 – Breaches of our policy
Any employee who breaches our policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We reserve the right to terminate our relationship with other third parties undertaking works on our behalf, including sub-contractors and suppliers, if there is evidence to suggest that they are in breach of our policy.