Modern Slavery Statement
Modern Slavery Act Transparency Statement for the Financial Year ending 31 March 2019
The Modern Slavery Act 2015 prohibits slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). Last Mile Infrastructure Group Limited (11534385) and its direct and indirect subsidiaries (the “Last Mile Infrastructure Group” or the “Group”) is committed to identifying and mitigating the risk of Modern Slavery occurring within its business or supply chains.
This statement sets out the steps taken by the Group in the Financial Year ending 31 March 2019 to identify and mitigate the risk of Modern Slavery occurring in its business or supply chains.
About the Last Mile Infrastructure Group
The Last Mile Infrastructure Group is organised into six operating companies*:
• Energetics Design & Build Limited (SC2324695) designs and builds gas, electricity and water infrastructure for residential, mixed-use and commercial developments in England, Wales and Scotland;
• Last Mile Gas Limited (SC303150) and Last Mile Electricity Limited (SC234694) own and operate installed gas and electricity assets (respectively) under licence from the Gas and Electricity Markets Authority (commonly referred to as the Office of Gas and Electricity Markets, or “Ofgem”);
• Last Mile Asset Management Limited (SC546822) carries out business development and asset management services for Last Mile Gas Limited and Last Mile Electricity Limited, including the adoption of new assets from Energetics Design & Build Limited as well as third party connection providers;
• Last Mile Meters Limited (SC573458) owns gas and electricity meters, and hires them to gas and electricity suppliers;
• Last Mile Infrastructure Limited (SC293480) employs the majority of our staff working across the Group.
* Last Mile Infrastructure Limited also holds a majority stake in UK Power Solutions Limited (06256696) which it acquired on 7 October 2019. For the purposes of the Modern Slavery Act 2015, UK Power Solutions Limited has published its own statement for FY 2018/19.
Our Head Office is Fenick House, Lister Way, Hamilton International Technology Park, Glasgow, G72 OFT. We also have offices in Warrington and Stonehouse, Gloucestershire. As at 31 March 2019, we employed 363 employees in total.
All of our employees are based in, and all of our work is undertaken in, the United Kingdom.
The Last Mile Infrastructure Group aims to identify and mitigate the risk of Modern Slavery occurring within its business and supply chains. The Last Mile Infrastructure Group has a responsibility to understand the risks in its business and supply chains and has a specific Modern Slavery Act Policy, which is approved by the Group’s Chief Executive Officer.
The Last Mile Infrastructure Group supports fundamental human rights and is committed to a safe workplace that values equal opportunity, and that is free from discrimination, harassment and victimisation.
The Group operates in a regulated environment and has robust policies and procedures concerning employment screening (including work eligibility checks and confirming that prospective employees are in possession of their own identity documents, including valid passports}, employment conditions and appropriate workplace behaviour.
All staff are expected to abide by the spirit, as well as the requirements of the Group’s policies and procedures concerning Modern Slavery, Whistleblowing, Anti-Bribery and Corruption and Equal Opportunities. A confidential helpline number is provided for employees to report breaches of these policies. All employees have access to a confidential 24/7 Employee Assistance Programme.
The Last Mile Infrastructure Group’s business is both office and field-based with the main supply chain categories comprising of:
• professional services in relation to utilities networks and connections;
• manufacturers and suppliers of construction materials for electric, gas and water connections;
• suppliers of plant, vehicles and equipment;
• sub-contractors providing specialist construction services; and
• recruitment agencies.
Based on the sector and supply chain profile, the risk of Modern Slavery is considered to be moderate.
We have reviewed the risk that our supply chains present and whilst we consider our exposure to Modern Slavery to be moderate, we expect our suppliers and sub-contractors to demonstrate a zero-tolerance approach to exploitation.
Our Modern Slavery Act Policy is now communicated to all suppliers and sub-contractors as part of our contracting processes, and they are required to confirm that no part of their business operations contradicts this policy.
The Last Mile Infrastructure Group is committed to ensuring that compliance with the Modern Slavery Act 2015 is at the heart of both its upstream and downstream supply chains and, to that end, is working to include compliance with the Modern Slavery Act 2015 in its customer vetting process.
The Group took the following steps in the financial year to which this statement relates:
• We reviewed our Modern Slavery Act Policy and enabled that policy to become embedded and understood throughout our business through internal and external communication.
• We reviewed our terms of employment to ensure that they comply with all relevant legislation.
• We implemented an Employee Assistance Programme, which includes 24/7 access to a confidential helpline.
• We revised our standard terms and conditions, to ensure compliance with the Modern Slavery Act 2015. The roll out process to suppliers and sub-contractors has begun.
Training and Capacity
Communication of our Modern Slavery Act Policy forms part of employee, contractor and subcontractor on-boarding procedures.
This Modern Slavery Act Transparency Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and was approved by the boards of each of the Last Mile Infrastructure Group companies, other than UK Power Solutions Limited.