administrations in particular showing a greater level of leadership on this agenda.” The Transparency in Supply Chains

provision only requires businesses to publish a statement if they have an annual turnover above a threshold of £36m. This means that the provision does not apply to a large portion of SME builders. Ghumra believes however that smaller

companies will “want to demonstrate what they’re doing, because they want to be recognised as being a more responsible and ethical business.” He also predicts the threshold will come down over time, and also that a more punitive element may be introduced.

SUBCONTRACTING The construction industry is built of tiers of subcontractors and specialists delivering programmes of work. This can lead to more unknowns, with the potential of agencies providing workers who have been coerced or abused, says Ghumra. “A number of contractors are looking at

agency providers and suppliers. If you own staff, they may have been on your books for a number of years, you may have recruited them directly and you or an employee may have a personal relationship with those employees.” The risk therefore starts to increase the further away you get from the

recruiting process, said Shamir. “Agencies, who you may have a great relationship with, can often subcontract out an element or geography of that work, and it becomes hard to know how many others are involved before you actually get to the person who’s being brought in to do the job.” He summarises: “It’s important to

research where your workers are coming from. The less you know, clearly, the greater the risk.”

STEPS FORWARD With modern slavery potentially endemic throughout the industry, it’s hard to know where to start. “You can’t do everything on day one,” said

Ghumra. “We need to recognise that there is no quick fix for the entire industry, or indeed any business; it’s an endemic world problem.” “To begin with,” he said, “it’s important to

sit down with the board or team, make a list and say, ‘what are our risk areas?’” Often, he says the focus is on either large

areas of spend, or particular product groups. “They might look at their overall spend on bricks and blocks, or natural stone, where is it coming from, and how much is sourced through agencies or other distributors whose workings you perhaps don’t fully understand? Who are the subcontractors? And how confident are you that they are not

subcontracting work further down the chain?” He continued: “A number of companies

I know of have started to review their procurement practices, and have a prequalified supplier list. They may say, for example, that an agency must not subcontract out any of the work, without first telling them who they are subcontracting it to, or at least making the client aware that that is what they are going to do.” He described how the BRE’s White Paper

details the elements that can make a company achieve Best in Class in any given ‘pathway’, rather than just meeting baseline requirements: “If we take reporting, for example, some of the best companies are willing to share, not only the great PR stories, but transparency in the areas that perhaps they found and were not too happy with.” He said that through “promoting good

practice and learning, companies may find common issues that were found on a particular situation, and can perhaps share how they’ve tried to remedy that and move forward.” Shamir concluded: “It’s important to

develop more collaborative relationships between in-house builders, labour and the public supply chain. By looking at what it is you do know about your supply chain, you begin to understand what you don’t know.”



 Performance, neatly packaged.

 

  

  

 

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