Modern Slavery and Human Trafficking Compliance Statement
Consistent with our commitment to operate our business in an ethical manner and in compliance with all applicable laws and regulations, Modulaire Group (“Modulaire”) is committed to improving our practices to combat modern slavery and human trafficking in our supply chains. Whilst we have already taken positive steps to comply with these principles, we continue to work with our suppliers and employees to ensure that slavery and human trafficking do not take place within our supply chains or our business.
Modulaire provides modular 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 through a variety of brands which include Elliott, Carter Accommodation and Advanté in the UK; Algeco, BUKO Huisvesting, BUKO Bouw & Winkels, BUKO Bouwsystemen and Altempo in Europe; and Ausco, NET Modular, Portacom and Algeco Chengdong in APAC. Further details about the Modulaire Group and its operations can be found at www.modulairegroup.com
Our Supply Chains
Our supply chains include: the manufacture of modular units; materials for buildings including steel components, walls and panels, insulation, electrical components, plumbing supplies and flooring; sub-contract services for certain delivery, installation, disassembly and repair/maintenance work; and IT and other business support services.
Our Policy on Modern Slavery and Human Trafficking
We are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Modulaire’s Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all of our business relationships. We continue to further that commitment by implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place at any level of our supply chains.
Due Diligence Process for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk, we vet the vendors that form our supply chain by way of assessing where those vendors are located and the sectors they operate in.
We have systems in place to:
- Identify and assess potential risk areas in our supply chains;
- Mitigate the risk of slavery and human trafficking occurring in our supply chains;
- Monitor potential risk areas in our supply chains; and
- Protect whistleblowers.
Supplier Adherence to Our Values
We have a zero tolerance attitude to modern slavery and human trafficking. To ensure that all those in our supply chain and our contractors comply with our values, we require vendors to adhere to our Supplier Code of Conduct, including a commitment to not use slave labour or participate in human trafficking. In addition, we seek express acknowledgement of adherence at the stage of on-boarding our suppliers.
Our Effectiveness in Combating Slavery and Human Trafficking
We have brought this statement to the attention of those in our Procurement teams 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 undertaking a further assessment of the risk of non-compliance in our supply chains.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we 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 organisation.
Group General Counsel
Last updated: March 2021