Ethical Labour Policy
Modern slavery is a criminal offence and a violation of
fundamental human rights. It takes various forms, such as
slavery, servitude, forced and compulsory labour and human
trafficking, all of which have in common the deprivation of
a person’s liberty by another in order to exploit them for
personal or commercial gain. Urban&Civic plc, and all of its
group companies, have a zero-tolerance approach to modern
slavery and we are committed to acting ethically and with
integrity in all our business dealings and relationships. We
are also committed to implementing and enforcing effective
systems and controls to ensure modern slavery is not taking
place anywhere in our own business or in any of our supply
We are also committed to ensuring there is transparency in
our own business and in our approach to tackling modern
slavery throughout our supply chains, consistent with our
disclosure obligations under the Modern Slavery Act 2015. We
expect the same high standards from all of our principal
contractors, housebuilders, suppliers and consultants. As
part of our contracting processes, we include specific
prohibitions against the use of slave, forced, compulsory or
trafficked labour, and we expect that all of our principal
contractors and housebuilders will hold their own suppliers,
contractors, sub- contractors and labour suppliers to the
same high standards.
This policy applies to all persons working for us or on our
behalf in any capacity, including employees at all levels,
directors, officers, agency workers, seconded workers,
principal contractors and housebuilders.
This policy does not form part of any employee’s contract of
employment and we may amend it at any time.
Our minimum labour standards
All migrant workers must be treated in accordance with the
requirements of all applicable laws and of our HR policies
and practices and will be subject to the same employment
contract terms as other potential recruits. All workers,
irrespective of their nationality or legal status, are
required to be treated fairly and equally.
Urban&Civic require that the following practices are
complied with by all principal contractors, housebuilders,
suppliers and consultants:
Workers shall not be subject to any form of forced,
compulsory, bonded, indentured or prison labour. All work
must be voluntary and workers shall have the freedom to
terminate their employment at any time without penalty,
giving notice of reasonable length as required by their
Workers must not be charged any fees for recruitment,
directly or indirectly, including costs associated with
travel, processing official documents and work visas in both
home and host countries
Workers will not be required to lodge deposits or security
payments at any time and must not have their identity
All employees must be provided with their employment
contract prior to beginning work. The use of supplemental
agreements aimed at undermining the terms of the employment
contract are strictly prohibited.
The workplace shall be free of any form of harsh or inhumane
treatment such as harassment, mental or physical coercion.
Sanctions that result in wage deductions or any practices of
equivalent effect are strictly prohibited.
All workers must be paid at least the living wage (as
published by the Living Wage Foundation) and must also be
provided with all benefits that are required by law. Clear
and transparent information must be provided to workers
about hours worked, rates of pay, and the calculation of
legal deductions. Wage payments must not be delayed,
deferred, or withheld and only deductions, advances, and
loans permitted by law or which are permitted by Urban&Civic
policies are permitted.
Working hours must be consistent with the requirements of
law and all overtime worked must be voluntary, unless part
of a legally recognised collective bargaining agreement.
If the recruitment and hiring is necessary, the labour
agencies that are engaged must operate in accordance with
the requirements of law and, if required, should be
certified or licensed by the competent authority. The
agencies/labour recruiters must not engage in any behaviour
that places workers at risk of forced labour or trafficking
for labour exploitation.
We require all of our principal contractors, suppliers,
consultants and housebuilders to have an appropriate system
in place for ensuring their employees receive training as to
the requirements of this policy and the Modern Slavery Act
Responsibility for the policy
The Board of Directors of Urban&Civic plc has overall
responsibility for ensuring this policy complies with our
legal and ethical obligations, and that all those under our
control comply with it.
Robin Butler, our Managing Director, has primary and
day-to-day responsibility for implementing this policy.
Compliance with the policy by Urban&Civic employees
You must ensure that you read, understand and comply with
The prevention, detection and reporting of modern slavery in
any part of our business or supply chains is the
responsibility of all those working for us or under our
control. You are required to avoid any activity that might
lead to, or suggest, a breach of this policy or the Modern
Slavery Act 2015.
You are encouraged to raise concerns about any issue or
suspicion of modern slavery in any parts of our business or
supply chains of any contractor, consultant, supplier or
housebuilder at the earliest possible stage.
If you believe or suspect a breach of this policy has
occurred or that it may occur you must notify your line
manager or Robin Butler as soon as possible. You should note
that where appropriate, and with the welfare and safety of
local workers as a priority, we may give support and
guidance to our contractors and suppliers to help them
address coercive or exploitative work practices in their own
business and supply chains.
If you are unsure whether a particular act, the treatment of
workers more generally, or their working conditions within
any tier of our supply chains constitutes any of the various
forms of modern slavery, please raise it with your line
manager or Robin Butler.
We aim to encourage openness and will support anyone who
raises genuine concerns in good faith under this policy,
even if they turn out to be mistaken. We are committed to
ensuring that no one suffers any detrimental treatment as a
result of reporting, in good faith, their suspicion that
modern slavery of whatever form is or may be taking place in
any part of our own business or in any of our supply chains.
Communication and awareness of this policy for Urban&Civic
Training on this policy, and on the risk our business faces
from modern slavery in its supply chains, forms part of the
induction process for all employees who are employed by
Urban&Civic. We will require all employees to complete
e-learning training on modern slavery.
Our zero-tolerance approach to modern slavery in our
business and supply chains must be communicated to all
principal contractors at the outset of our business
relationship with them and reinforced at regular intervals
Any employee who breaches this policy will face disciplinary
action, which could result in dismissal for misconduct or
We may terminate our relationship with other individuals and
organisations working on our behalf if they breach this
Chairman of the Board of Directors of Urban&Civic plc
4 February 2020