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Slavery and human trafficking statement

Introduction

As a leading global consultancy, we have a responsibility to use the influence we have, through delivering some of the world’s largest infrastructure projects, to make a positive change for those who need it most.

This is captured in our Purpose:

To improve society by considering social outcomes in everything we do; relentlessly focusing on excellence and digital innovation, transforming our clients' businesses, our communities and employee opportunities.

A key part of this is our approach to addressing modern slavery and more widely respecting human rights. We reject modern slavery in all its forms, including servitude, forced or compulsory labour, child labour and human trafficking. We recognise that there are risks of modern slavery in every country and any industry and aim to work only with suppliers whose policies and procedures support our own approach.

This statement confirms our compliance with Section 54 of the UK Modern Slavery Act 2015. In setting our policies and processes we aim to follow best practice as well as the UK Government guidance ‘Transparency in supply chains’. In addition to publishing this statement on the Mott MacDonald Group website, we will also publish it on any associated websites to promote our commitment to this agenda.

This statement covers the whole of the Mott MacDonald Group and its worldwide operations, with the exception of our JN Bentley business based in the UK. It should be noted that our business in Australia (Mott MacDonald Australia Pty Limited) has also published a Modern Slavery statement in accordance with the Modern Slavery Act 2018.

Mott MacDonald's organisation's structure:

Mott MacDonald is a US$2bn engineering, management and development consultancy involved in:

  • Solving some of the world’s most urgent social, environmental and economic challenges
  • Helping governments and businesses plan, deliver and sustain their strategic goals
  • Responding to humanitarian and natural emergencies
  • Improving people’s lives

Our expertise by sector include advisory, built environment, energy, international development, transport and water. Our skills encompass planning, studies and design, project finance, technical advisory services, project and programme management, management consultancy and beyond.

Our PRIDE values – Progress, Respect, Integrity, Drive, and Excellence – guide our behaviour, shape our culture and inform our relationships with our clients, stakeholders and each other.

Being employee-owned frees us to choose the work we take on and focus on the issues that are important to our clients – and us. We’re not in business to make the most profit for external shareholders: we want to do a great job for our clients, our communities and our people. We insist on the highest standards of integrity in all we do. We were the first consultancy firm to be certified to BS 10500, the UK’s anti-bribery management standard. We have built on this and our anti-bribery management system is now certified to the international standard ISO 37001.

We operate globally with one corporate set of policies, directives and requirements through a common online business management system. Through this approach, all our colleagues in the Mott MacDonald Group, whether employed in the UK company or around the world are required to comply with the UK Modern Slavery Act 2015 as well as any national legislative requirements, for example the Modern Slavery Act 2018 in Australia.

Our supply chain

We recognise our responsibilities to ensure that our supply chain complies with International Labour Organisation conventions and have proper respect for the people supplying services to them. We are committed to achieving the ethical standards we set for ourselves with our supply chain and continue to work towards full transparency. Modern slavery aspects are included in our standard supplier and joint venture contracts in the UK.

The modern slavery risks the business faces can broadly be divided into the following categories of supply chains in our business operations:

  1. Facilities management (FM) staff (office cleaning, janitorial, security, etc.) in our 140 offices across the world.
  2. Organisations providing resources or services to support the delivery of our business, such as suppliers of personal protective equipment, office supplies, catering organisations, accommodation and travel companies.
  3. IT and other office equipment, such as furniture

The above groups can be further subdivided into labour that is:

  • Directly employed (MML group companies being the contracting party)
  • Sub-contracted, where we employ a service agency who is the contracting party
  • Associated labour, whereby our joint venture (JV) partners are the contracting party, or they sub-contract to agencies to provide labour

In all cases we seek to ensure that our purchasing practices do not create pressure on our suppliers that could lead to modern slavery for example, avoiding aggressive pricing that does not consider production costs, late payments or imposing unfair penalties.

In our UK and Europe region all our approved suppliers are held on a central database which staff can consult prior to engagement. Those we have identified as higher risk such as our central UK facilities management contract, our personal protective equipment supplier and our furniture suppliers are subject to additional questions at tender stage and during regular contract reviews. We also carry out some spot checks for payments of a living wage and audits for working conditions at manufacturing facilities.

Our policy

Our approach to respecting people and our suppliers is also embedded in our policies on slavery and human trafficking, equality, diversity and inclusion, ethics, human resources, risk treatment, procurement, safeguarding, and social responsibility.

To see our full set of policies click here

Due diligence process

As a predominantly professional services body, the vast majority of Mott MacDonald’s direct employees are not considered vulnerable, or at risk from modern slavery. In relation to slavery and human trafficking in our business, we:

  • Employ individuals through an interview process, whether they are full-time employees or contract staff. This process seeks to confirm individuals share our corporate values, have a right to be employed for a specific job, are not breaching immigration regulations; have the necessary competence and aptitude for the position and are applying to work for us through their own free will.
  • Seek to provide a living wage for all directly employed staff.

In our supply chain, we evaluate all potential and existing suppliers using a standard questionnaire to identify competence, compliance with our values and standards and to ensure they are addressing slavery and human trafficking risks. This assessment is repeated periodically. The process is supported through our procurement processes. We are currently reviewing our global approach to procurement to identify best practice and strengthen this area in the future.

Due diligence on clients and suppliers is undertaken through combining our previous experience of working with the organisation, our local knowledge of them and the information surfaced through the Exiger Insight3PM service. This consists of an initial web- based search on a company and its affiliates, with a more comprehensive review available if needed.

We verify that we hold up-to-date and accurate information about our suppliers, supported by our supplier questionnaire prior to engagement. We check they comply with the requirements in our policies on modern slavery, ethics and anti-bribery, and they divulge essential financial and structural information to us. Following appointment, suppliers are assessed annually via a formal record of performance.

Risk assessment

As stated, as a professional services organisation, our risks associated with slavery and human trafficking of direct employees are generally low. Our professional staff have tertiary education, are often members of professional organisations and command significant levels of compensation in line with market norms.

It is acknowledged that our risks related to modern slavery vary between the countries and sectors we work in.

We have carried out a preliminary geographic risk assessment which we will continue to develop over the coming years. We are currently working on how we might use the Global Slavery Index to identify the specific areas in our supply chain that might pose a higher risk for modern slavery, looking at both location and sector.

To support the business we have produced best practice guidance for our project managers and teams to help them identify key areas of risk and to implement appropriate control measures to mitigate the risks. This has been integrated into our health and safety risk assessment process and training has been provided to our global safety managers and project safety advisors to support project staff. The areas of risk identified can be broadly grouped as:

  • Outsourced low wage jobs, such as office cleaners, drivers and support staff
  • Our commodity purchasing supply chain eg personal protective equipment, IT equipment, office furniture, tea and coffee, where unskilled labour is prevalent
  • The construction related supply chains of our partners and clients around the world
  • Staff untrained in recognising the signs of modern slavery
  • Working with joint ventures (JV) and sub-consultants
  • Failure to report and investigate suspected modern slavery issue

Whilst we interface closely with the construction industry around the world, we do not undertake traditional construction activities with the exception of the J N Bentley business in the UK. The JN Bentley modern slavery statement can be found here.

Effectiveness of our approach

As we deem the risk of slavery and human trafficking in our own business to be low, we monitor the performance of our suppliers in supporting us to meet our policy commitment and the services they provide to us. We also monitor our own compliance with our employment and procurement processes. In addition, we are audited around the world by third party organisations both for compliance with our internal business processes and with quality standards. We are confident this approach is appropriate to managing our risks for our tier one suppliers.

Speaking up

Our Speak Up helpline is a comprehensive and confidential internet and telephone-based reporting tool provided and managed by an independent third party (Navex Global – EthicsPoint). We have strict processes in place which are published on our intranet as part of our business management system. The service is promoted through campaigns within the company, including via posters in our offices. It is accessible to anyone, including all tiers of our supply chain including facilities management staff in all of our offices. Reports are treated confidentially and can be raised anonymously where local legislation allows. During 2020 we did not receive any reports (internal or via Speak Up) related to modern slavery or human trafficking.

Training and awareness

We train all our staff on ethics and compliance with our values, directives and processes. We also provide training on people management and communications skills and these are directly aligned with our PRIDE values. This creates a strong culture of tolerance of others, transparency in decision-making and mutual respect, that supports our training module on Modern Slavery which is available to all staff.

In addition, in 2021 we will be launching a new Code of Conduct, called Our Code- Delivering with PRIDE for our staff and those who work with us. This will contain our standards and the expectations for all our staff on Modern Slavery and human rights. All staff within the business will be expected to complete training on Our Code and to read and certify that they have complied with it. Our Code will also be made available to our suppliers and will highlight our desire to work only with those who can meet our standards and expectations, including aspects relating to Modern Slavery and human rights. Our Code will help all those who work for us, or with us, to improve their understanding of Modern Slavery and how to raise any concerns, should they come across any.

Once all staff have a basic understanding, we aim to carry out a training needs analysis to identify which staff would benefit from enhanced training, ie those who are more likely to come into contact with victims of modern slavery. We expect this to be a minority of staff involved in managing supplier contracts.

In 2021 we are intending to run a campaign of internal communications around Modern Slavery to coincide with the publication of this Modern Slavery Statement.

Our progress in 2020:

  • We published risk management guidance for our project managers on Modern Slavery and mitigating actions and introduced a new project management requirement to ensure that modern slavery issues are considered at the start of relevant projects, at the same time as health and safety risks. This includes consideration of sector, country and suppliers.
  • We updated our confidential Speak Up helpline to include an increased number of in-country numbers for the countries in which we work and dedicated helplines for our hub countries. As part of this, an awareness campaign was carried out including physical posters in our offices. This will continue to be promoted into 2021 as part of the launch of Our Code – Delivering with PRIDE.
  • We brought the management of our social compliance agenda related to both safeguarding and modern slavery into our health, safety and wellbeing team. This is in addition to the Group’s increased focus on delivering social outcomes in 2020. As part of this we rolled out modern slavery briefings to our global safety community to assist them in advising the wider business of the new risk management processes.
  • Spot checks were carried out on our highest risk UK suppliers to ensure that their staff were being paid a living wage.
  • We created a focus for modern slavery on our intranet pages with key contacts, how to spot the signs of modern slavery and what to do and links to relevant resources.

Plans for improvements to our approach in 2021

We have agreed a number of actions for 2021 summarised below:

  • We will specifically include modern slavery as part of our new Code of Conduct for all staff and those working on our behalf. This will cover key principles and actions for everyone, will be launched in late 2021 and will be supported by additional training material which we will be able to update based on current priorities.
  • All our suppliers will be asked to confirm that they are working to and implementing equivalent standards as part of their contract with us.
  • We are undertaking a review of our due diligence process to explore how we can better identify our highest risk suppliers and constructively engage with our supply chain on modern slavery and human rights issues. This goal is likely to extend beyond the current calendar year because of the size of the organisation, and trialling any new systems developed will take place in one geographical area before any further roll out.
  • We are reviewing our procurement process for our large UK contracts to explore how we can better assess our suppliers for modern slavery issues at the tender stage and during contract reviews.
  • We will share the UK procurement approach with the wider business, through establishing an internal network of regional procurement contacts and using this network to share best practice.
  • We are working to better understand and develop risk ratings for countries we work in, using the Global Slavery Index. Outcomes from this work will be fed into our risk assessment approach in our business management system.
  • We are working to increase our external engagement with NGO’s, competitors, clients and suppliers on Modern Slavery issues.
  • By 2022 we will make it mandatory for all major bids and prospects across our global business to consider positive social outcomes, including modern slavery risk mitigation in our operational supply chains.
  • By 2022 we will incorporate questions about the delivery of social outcomes, including modern slavery risk mitigation, into the interview process for all project-based principal consultant positions and above.

The above statement has been approved by the Executive Board of Mott MacDonald and is signed on their behalf by Mr James Harris, Group Managing Director.

James Harris
June 2021

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