Modern Slavery Statement

Modern Slavery Statement 2024 Quinn (London) Limited

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Quinn (London) Limited and Quinn Investment Holdings (London) Limited for the financial year ending 31 May 2024, to prevent Modern Slavery and Human Trafficking in its own business operations and supply chains.

A message from our joint Managing Directors

As joint managing directors of Quinn (London) Limited we, and all the Directors from the holdings and operational company, are committed to combating modern slavery in all its forms. This annual report highlights our dedication to ensuring that our operations and supply chains are free from human trafficking, forced labour, and child labour. We pledge to uphold transparency and accountability, working diligently to prevent and address the risks of modern slavery within our business activities.

We shall continue to be vigilant by on-going training and support for our staff and our supply chains, to ensure that we neither encourage, by our actions nor inactions, anything which might lead to people becoming the targets of unscrupulous and unfair practices.

Avoiding modern slavery in the modern era, is as important as the lessons learned from historic slavery.

Introduction

This statement covers the parent company, Quinn Investment Holdings (London) Limited, and the subsidiary company, Quinn (London) Limited. Patrick McGrath and Gerry O’Connor, the Managing Directors of the parent and subsidiary company approved this statement on 31 May 2024 and will review and update it annually.

At Quinn (London) Limited, we recognise the profound importance of addressing and combatting modern slavery in today’s globalised world. Both a crime and a violation of fundamental human rights, Modern Slavery takes various forms, such as slavery, servitude, forced and compulsory labour and Human Trafficking, all of which have in common the deprivation of one’s liberty by another to exploit them for personal or commercial gain. As a responsible and ethical main contractor, we are committed to upholding the highest standards of human rights, social responsibility, and ethical business practises.

Our robust approach to tackling Modern Slavery is influenced by a combination of legal obligations, ethical considerations and the recognition that responsible business practices are essential for long-term success. As part of the construction industry, we recognise that our industry has one of the highest rates of Modern Slavery in the UK, and we are committed to playing our part in identifying risks and implementing policies to ensure the eradication of Modern Slavery and Human Trafficking in our business and supply chain.

This statement sets out actions we have taken to understand the potential Modern Slavery risks related to our business, and steps we have put in place that are aimed at ensuring there is no slavery or human trafficking in our group of companies.

Key Focus Areas

In 2023/2024 we have focused on three key areas:

  • Analysis of our Supply Chain spend to allow effective engagement, provision of transparency and assurance in respect of Modern Slavery
  • Continuing to broaden awareness of the risks of Modern Slavery through the provision of training to a wider group of staff within our business
  • Successful implementation of a new
  • HR software, ELMO, to allow for better onboarding, specifically the monitoring and tracking of employee Right to Work checks

Governance Structure

At Quinn (London) Limited, we strive to provide training and raise awareness on Modern Slavery, with particular emphasis on our HR and Supply Chain departments, to ensure our employees are able to identify risks of Modern Slavery and take appropriate action if necessary. Accountability for Modern Slavery within our operation falls with Imran Karim, our Finance Director, reviewal and final sign off sit with our Joint Managing Directors, Patrick McGrath and Gerry O‘Connor.

Organisational Structure & Supply Chains

Founded in the year 2000, Quinn (London) Limited is an award- winning, privately owned Construction company, that has excelled into becoming one of the leading main contractors in London; where we continuously thrive on the challenge of working in England’s diverse construction landscape. With an annual turnover of almost £100 million, our work has had a huge impact on the capital, and we are committed to working alongside other organisations, suppliers and sub-contractors who equally support the aim of reducing modern slavery across the UK. At Quinn (London) Limited, we have 3 specialist divisions, Property Services, Central London and Heritage, covering Social Housing, Healthcare, and Grade listed buildings; as well as a Head Office division, which oversees all 3 specialist divisions. We currently operate from 2 offices, with 35 active project sites.

Over recent years we have carefully expanded our operations without over-leveraging our resources, allowing us to organically build up skill and equity in our business and become more competitive in the current market conditions. As a result, we offer our clients certainty and reliability, a reputation which is invaluable. Over 50% of our business is derived from repeat business – a direct result of our clients experiencing high quality of service on our projects.

Our Supply Chain includes the procurement of trade subcontractors, material and plant suppliers, consultants and other service providers to meet our business requirements. Our goal has always been to partner with business that embrace our core values and exemplify a genuine dedication to ethical and honest dealing.

The company’s supply chains fall under the following main categories:

  • Subcontractors
  • Consultancies
  • Supply Only and Hire Companies

 Quinn London Divisions:

Central London Division

  • NHS Bodies
  • Health and Social Care Providers
  • Emergency Services Authorities
  • Government Departments
  • Academic Institutions
  • Charities and Third Sectors

Heritage Division

  • Museum and Arts
  • Conservation

Property Services Division

  • Housing Associations
  • Local Authorities

Working with approved subcontractors – 396

Employing staff – 167

Working with suppliers – 73

Serving clients – 75

Policies in relation to slavery & human trafficking

We have a number of policies within our Company, which are designed to manage the risks relating to Modern Slavery and Human Trafficking within our business.

  • Anti Bribery and Corruption Policy
  • Anti Slavery and Human Trafficking
  • Mental Health and Wellbeing Policy

Our HR Department maintains our policies, regularly reviewing and updating them where necessary to accommodate changes to our business, the laws that apply to us, and best practises.

Collaboration & partnership working

We recognise the importance of collaborating with organisations to manage the risks of modern slavery and human trafficking within our industry. At Quinn (London) Limited, we recognise that those subjected to modern slavery may be under duress, therefore, we have partnered with mental health charity, Lighthouse, to provide support to employees. We also have designated mental health first aiders at all levels of the business within our different divisions.

Quinn (London) Limited is a proud member of the London Living Wage, we believe that this commitment helps to significantly reduce the risks of individuals working at our sites being paid below the national minimum wage, a key modern slavery risk.

We will continue to explore opportunities to work with other organisations to strengthen our anti-slavery efforts and work in support of eliminating modern slavery within our business and supply chains alike.

Due diligence processes

Whilst we have a thorough due diligence process in place for managing both new and existing supply chain relationships, we continue to regularly review these to ensure that the intention and requirements of the act are addressed. When working with our supply chain partners we ask that they provide us with the assurance that modern slavery is understood and not present in their company and wider supply chain. We want to ensure safe and fair working conditions are provided, and we require that those in our supply chain have policies, procedures, practices and contracts within their organisations and with their own suppliers to equally reflect this.

Quinn (London) Limited regularly reviews our trading partners as part of our supply chain management, focusing closely on those we consider to be at the greatest risk, including suppliers who operate by employing casual or temporary labour, manufacture or trade in raw materials, particularly outside the UK / EU. They need to demonstrate to us, full compliance with our policy and this statement. We have reviewed our standard purchase orders that are used to engage with our supply chain to assess and manage any risk, as far as is reasonably practicable. To support our approach further all of our subcontract orders and purchase orders have an appropriate paragraph included as standard, regarding the Modern Slavery Act.

Quinn (London) Limited has mandatory requirements for potential additions to its supply chain to be accredited via a Safety Schemes in Procurement (SSiP) governing body which is verified via the SSiP Forum, further checks can be made via member portals to cross verify which modules the proposed contractor is certified. Quinn (London) Limited has also adopted the Common Assessment Standard (CAS) across the business for its PQ process when onboarding any new contractor which includes questions from the now withdrawn PAS91:2013 required to be answered surrounding Modern Slavery Legislation.

Our Supply Chain Database identifies which companies over the turnover threshold of £36m required by law to have a policy statement but we promote collaboration with SME who fall below the required threshold. They are required to submit evidence and or provide statements as to how they develop themselves and their workforce surrounding modern slavery techniques as well as outline any risk mitigation strategies for the company as a whole.

 Quinn (London) Limited strives to:

  • Ensure that all eligible workers are in receipt of the London Living Wage or National minimum wage and robust immigration checks are in place
  • Ensure that labour sourcing, recruitment and worker placement processes are under control of trusted and competent staff
  • Not to use any individual or organisations to source or supply workers without confirming the workers are not being charged a work finding fee
  • Provide appropriate information, instruction, resources and training necessary to educate the workforce and supervisors
  • Positively encourage workers to report cases of exploitation, providing the means to do so, and protecting whistle-blowers and act upon reports appropriately

Risk assessment & management

As a construction firm, we work in partnership with subcontractors and other suppliers to meet our obligations to our clients. We have carried out a risk assessment of our operations and consider that risk of Modern Slavery is present in the ranked order, as follows.

  • Small subcontractors, who are engaged on work packages, which are imbalanced to their number of directly employed employees
  • When work is further subcontracted, as control may be lost
  • Temporary labour sources by unregistered labour agencies
  • Staff engaged locally to each project, through labour agencies
  • Local Authorities in advancement of their own local labour initiatives
  • Materials suppliers, who are most likely to have a larger turnover than Quinn (London) Limited
  • Directly employed staff

Therefore, our action plan has been set up to deal with these on an on-going basis. As part of our ongoing duty to identify and mitigate risk we have in place systems and processes to:

  • Regularly monitor labour and payroll
  • Provide appropriate training
  • Protect and support any whistle blowers
  • Identify and assess potential risk areas in our supply chains; and
  • Monitor potential risk areas in our supply chains and put in place actions to mitigate those risks
  • Build strong relationships with our supply chain and make clear the Group’s expectations as to their conduct
  • Include the Act’s requirements as part of our procurement process and clearly set out our expectations

Key performance indicators to measure effectiveness of steps being taken

During our current financial year ending 31 May 2024, we continue to monitor the effectiveness of our actions against modern slavery and human trafficking and review the risks within our own business and across our supply chain. We continue to provide further guidance and support to all employees and Supply Chain Partners to raise awareness within our industry.

Actions to ensure continuous improvement include:

  • All staff to complete an updated training module on Modern Slavery on an annual basis
  • Review our existing Supply Chain and ensure that they sign up to our new and revised supply Agreement
  • Review orders placed and sizes of company, to highlight potential for risks
  • Continue to rely on accreditation systems (CHAS and Constructionline)
  • Participate in collaborative initiatives focused on human rights, such as “stronger together”

Training & awareness

Modern Slavery training is delivered in the form of Toolbox talk, for all site workers. This is normally delivered to relevant Site Managers and Contracts Managers, for them to ensure that staff at all levels are aware of Quinn London’s commitment to outlawing the practices and implications of Modern Slavery. For all other employees, training is delivered on-line.

Supply Chain & Procurement Manager

Ensuring full compliance and adherence when suppliers are above £36m, which is checked within the pre-approval processes for our supply chain database.

Site Manager

Though observation and collation of information during inductions, with risk areas being failure to engage in speech, lack of CSCS card or next of kin details, including addresses and phone numbers.

SHEQ Manager

Observations made during site audits for tell-tale signs of likely risk areas, which is checked though the on-site induction process, and spot checks made by SHEQ inspectors. To ensure a good level of understanding of the risks of modern slavery and human trafficking in our business and supply chain, we will endeavour to provide relevant training to members of staff and a general briefing to all employees. We aim to train staff, on an ongoing basis on the requirements of the Modern Slavery Act, and its intentions. Staff training will be based on their role within the company, but we hope by 2025 that all of our employees will be up enrolled in Annual refresher courses. We will also be looking to nominate a main Board Director to oversee implementation and on-going monitoring.

As well as training staff, we have raised awareness of modern slavery by distributing information to all of our employees across our HR platforms. We are committed to:

  • Encourage the reporting of suspicious hidden worker exploitation to the Gangmasters Licencing Authority and Police
  • Reviewing our supply chain to identify risk areas and suitable due diligence control measures
  • Not knowingly support or deal with any business involved in slavery or human trafficking

2023/2024 Incidents:

  • We did not detect, nor were we made aware of, any breaches on Modern Slavery
  • There were no Statutory Disclosures during the year

Responsible recruitment

Our central HR and procurement functions enable us to ensure responsible recruitment practices and allow a better understanding of potential risk areas.

At Quinn (London) Limited, we adhere to stringent validation protocols, that are overseen by HR and our Procurement team, such as the below.

  • CSCS cards for operatives on sites
  • UK Passport and/ or Driving Licence
  • National Insurance Number
  • Work Permit
  • UK Residency Permit

Quinn (London) Limited’s procurement orders formally identify consequence for breaches of legal requirements, to all our supply chain. Where a breach occurs, contracts will be created with an alternative supplier, prior to formally ending it with the company in breach.

Employees are vetted during our pre-engagement process, by our HR team. In the event that a non-compliance is identified, potential candidates will be excluded from the recruitment process and Quinn (London) Limited will inform relevant authorities of the breach identified.

Employees are made aware within our HR handbook and their Terms and Conditions of employment of the company’s and their own responsibilities. Employees who fail to apply the Terms and Conditions of employment and/ or law, or disregard it, will be dealt with under our disciplinary system, which ultimately could lead to their dismissal.

Board approval

Our Finance Director, Imran Karim, is the main board director with formal responsibility for the  application and monitoring of our duties under the Modern Slavery Act.

The statement was approved by the Joint Managing Directors, Patrick McGrath and Gerry O Connor, and signed by the group Chairman Seamus Quinn, on behalf of Quinn (London) Limited and Quinn Investment Holdings (London) Limited.

This statement is reviewed annually and published on the Governments’ portal.

Seamus Quinn

Group Chairman