Our policy statement
At Astins we are committed to running our business responsibly. We strive to maintain high ethical principles, that are aligned to our business values and to respect human rights. It means doing our best to encourage high standards in our supply chain and our business.
In this document we describe our business and supply chain. We explain our current policies and practices, and the plans we are formulating in light of the Modern Slavery Act.
Our business and supply chain
Astins is a specialist sub-contractor delivering drylining, ceilings and internal fit-outs to Main Contractors, Owner Clients, and Architects from design inception to installation. Our experience and reputation for excellence extends to both private and public sector clients. We target projects within the United Kingdom and continental Europe and work on some of the most prestigious projects in the construction market
The business’ guiding values are:
• Opportunities for all
• Continuous improvement
• Fanatical attention to detail
We employ a total of 235 people and this is complemented with additional people sub-contracted through the Construction Industry Scheme (CIS), to meet the fluctuating needs of the business.
We buy a large range of items from plasterboard, metal stud, timber and other construction materials through to company clothing and waste disposal services. Around 150 suppliers sell to us, and in addition, some of these suppliers have their own suppliers. We prioritise our attention to our supply chain on companies that provide high value/volume products or services, or things without which our business could not operate. We are currently mapping, in detail, our supply chain to reflect the Modern Slavery Act, with the aim of understanding where the risks lie and putting in place actions to mitigate those risks.
Our stance on modern slavery
We have a significant number of current policies in place that are focussed around business ethics and treating people fairly in line with our business values. In line with our value ‘opportunities for all’ we have a long-standing commitment to ensure everyone is treated with dignity and respect and given an equal opportunity to employment and career advancement; which is reflected in our equal opportunity policy. This is ably demonstrated through our approach to apprentices both male and female, where we set no age limits on those who wish to go through our apprenticeship scheme. Also, our “graduate” programme does not require people to have had the benefit of a university education.
Our training plan includes training our head office and site management staff on good HR practices, including training on policies such as; business ethics & compliance, whistleblowing, anti-bribery, equal opportunities, recruitment and selection, to ensure that the highest standards of business ethics are achieved and maintained.
We also communicate these policies through the induction process and through other communication channels, e.g. noticeboards, flyers in payslips, company magazine, to enable all of our direct and indirect workers to not only feel part of the Astins community but also to remind them of their duties and responsibilities in maintaining the highest of ethical standards.
We encourage our people to speak up about any unethical behaviour and make it easy for them to do so via their line manager or direct to the HR team. In addition, the Directors’ of the business hold ‘breakfast clubs’ at a site level where workers volunteer to attend. The meeting is such that there are no managers or supervisors present during the meeting; this enables the workers to speak more freely. A worker can ask to chat to the Director on a one to one basis if they have concerns they do not want to raise in public.
As a result of the Modern Slavery Act we are looking at how we can make it even easier for our people to raise concerns, perhaps through the use of technology. This is incorporated into our plan that is being developed to enhance our ability to eradicate modern slavery.
We have launched our Astins “Speak-Up” campaign. We have posters on-site and cards are also handed out in four languages with our phone line and email address: firstname.lastname@example.org
How we check compliance with our standards
We aim to prevent modern slavery or human trafficking in our business right at the start of our recruitment processes. We have a recruitment policy that aligns with our business values and ethics. All of our direct employee recruitment is controlled through our HR department, even if people are presented through employment agencies, our HR department still carries out due diligence on each employee. Some of our workers are employed through the Construction Industry Scheme (CIS), this in effect means that we could hire a sub-contractor to carry out work and we will not have visibility of their workers. This changed in 2017 and is continuing to change, as we have updated our sub contract terms & conditions to reflect the requirements of the Modern Slavery Act. In addition, an internal audit process has been set up to give sub-contractors the opportunity to demonstrate to us that they are behaving ethically and are compliant to all relevant legislation. Our recruitment policy and agency contracts were updated during 2017 to make our requirements and expectations expressly clear.
Once people join us, they are expected to live up to our business values and ethics. We give our people plenty of support, education and training. But if they do not live up to our values and policies and choose to work unethically, we would take disciplinary action against them, which ultimately could lead to dismissal.
We are currently undertaking a thorough review of all operational processes to identify parts at risk of slavery and human trafficking. Once we have completed this process, we will determine the right things to do next. In line with our business value ‘continuous improvement’ we will review and refine the steps we take to identify any potential incidence of slavery or human trafficking.
The steps we take for our supply chain will depend on the outcomes of our initial risk assessment of the supplier. We will ask all of our suppliers to complete our ‘speaking up’ questionnaire. We will also use certifications and accreditations to professional bodies as one of the elements in helping to determine the level of risk a business may have.
Further risk profiling will be developed during 2018 to enable our resources to be focused on the higher levels of potential risk.
We received the questionnaires back from our suppliers in 2017 and built an audit programme to visit their sites to understand the risk in more detail. We may consider using third parties to support and complement the audit programme.
We keep our processes under review, and as the Modern Slavery Act implementation matures, we will respond accordingly to deal with any issues raised.
Helping Astins’ people to learn and champion the issues
A communication plan is in place to ensure everyone that either works in our business or is a supplier to it, will continue to be made aware of the requirements of the Modern Slavery Act and the expectations that everyone will adhere to these standards.
We require all Head Office staff, site management and supervisory staff to complete training on modern slavery. A module will be incorporated within the organisation’s wider training programme covering all relevant policies with a focus on human rights, ethics and the Modern Slavery Act. This will enable our people to understand and identify slavery and human trafficking risks, and remind them the varied ways they can report their concerns.
Our buying team will be integral in helping our supply chain to understand the issues around modern slavery and human trafficking and will be given the training and support to Champion our values and ethics across the whole supply chain. They are free to raise concerns to the Senior Leadership Team should they suspect any wrong doing.
Measuring how we are doing
We currently measure our business KPI’s using the scorecard methodology. KPI’s are in development to enable the various audit programmes to be tracked and for deficiencies to be identified. The business scorecard is reviewed at the monthly board meeting; thus enabling the Directors to respond with agility if issues are uncovered. KPI’s relevant to the Modern Slavery Act are on the 2018 business scorecard.
As part of the continuous improvement programme, we will be developing a comprehensive plan to address the risks of slavery and human trafficking. Longer term, we will look at developing better ways of measuring the effectiveness of our interventions to manage these risks. And each year we will share with you how we have progressed and the lessons learned.