PBA is committed to social and environmental responsibility and has zero tolerance for slavery and human trafficking. As part of this commitment, we have adopted a Code of Conduct to which we hold ourselves and our supply chain accountable. This statement covers the activities of Peter Brett Associates LLP (PBA) and all of our subsidiaries.
PBA operates mainly within the UK across 18 office locations providing infrastructure and development consultancy services. We also have a small international presence within the Czech Republic with two small outposts in Bratislava and Potsdam. Our international operations also adhere to this Code of Conduct.
The Code of Conduct prohibits the use of forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery, or trafficking of persons.
As part of our Quality Management System we carry out a review of our suppliers during the engagement process. Suppliers are required to demonstrate that they provide safe working conditions when necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. PBA works with the suppliers to ensure that they meet the standards of the code and improve their working conditions.
We have also established a Preferred Suppliers List with a select number of recruitment agencies and our HR team work in partnership with them to ensure that they meet the standards of the code. As well as this, we have strict recruitment procedures in place to ensure that we employ people legally, in a fair and consistent manner, and that the remuneration we offer to our employees is aligned with the national minimum wage or above. We apply these principles to all recruitment activity we undertake across the practice.
PBA also has a number of policies that help support the approach to, the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These include policies and procedures around Conduct, Ethics and Anti-Bribery, Whistleblowing, Fair Wage requirements, Reference checking and (where applicable) Disclosure and Barring service checks. These principles reinforce and strengthen our commitment to the rights of our employees, workers in our supply chain, and workers in the global community.
PBA is taking a variety of actions to verify the absence of forced labour, slavery, and human trafficking in our supply chain, including the following:
1. VERIFICATION AND RISK ASSESSMENT:
A detailed sub consultant assessment is carried out on initial engagement and reassessed every three years thereafter. This assessment incorporates risk factors including human rights risk and country governance and accountability, and has been enhanced to incorporate statements relating to Anti-Slavery and Human Trafficking.
An ad-hoc internal assessment of supply chain risk is carried out based on supplier performance and other indicators of supplier-specific risks.
Those suppliers considered to be low risk, due to the nature of the services provided and/or the type of organisation, may be exempted from this verification process.
2. SUPPLIER CERTIFICATION:
Certification is requested from suppliers to ensure compliance with all applicable laws, including those related to freely chosen employment. Supplier sites which may pose a high risk may be audited, and supplier sites demonstrating known risk factors for human trafficking may be audited as well.
3. INTERNAL ACCOUNTABILITY:
Internal accountability standards and procedures are in place to help confirm that employees and suppliers meet standards. These are intended to ensure that employees, workers and suppliers are aware of and adhere to established standards and processes. Supplier accountability occurs through mechanisms ranging from performance feedback to internal quality supplier reviews.
PBA also maintains corporate-wide accountability and grievance mechanisms (e.g., our whistleblowing policy and grievance procedures), which are available to both employees and other external parties.
Senior management of the Practice have been made aware of and are supportive of the Anti-Slavery and Human Trafficking Act and our Code of Conduct supporting this. Others within the Practice with responsibility for procurement and/or recruitment will be given training over the following 12 months on our approach to the Modern Slavery Act alongside our Supplier Code of Conduct through a variety of training approaches, from bulletins to workshops.
Our focus on slavery and human trafficking is part of a larger effort to encourage supply chain transparency and accountability. We will not tolerate forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery, or trafficking of persons by any supplier or for any other purpose.
The Management Board is responsible for the regular review and updating of this statement on an annual basis and it is approved by all the members of the LLP.