Corporate Policies at Andrews Sykes

Health and Safety

Health and Safety is a key priority for Andrews Sykes, whether it involves our employees, customers, suppliers or the local environments in which we operate. Our aim is to create an accident-free workplace and we are committed to continuous improvement in the effectiveness of our Safety Management System in conjunction with ISO 45001:2018.

Our commitment:

Effective safety management requires the involvement of employees at all levels. All employees have a duty to co-operate in the operation of this policy by:

Environment

In respect of the environment, we are committed to continuously improving our Environmental Management System, preventing pollution arising from our activities, products and services, in line with ISO14001:2015

To ensure this Environmental Management System is fully implemented, we are committed to:

Reducing, reusing and recycling materials and resources where possible
Training, awareness and communication
Working in partnership with our suppliers to ensure sustainable sourcing of products and materials
Integrating environmental considerations into business decisions

All employees are responsible for ensuring that their working areas are operating in accordance with our environmental standards and that they report any environmental issues to their line manager.

Quality

Andrews Sykes UK branch network is ISO9001:2015 certified.

Our commitment is to:

Pursuing a quality environment in partnership with its suppliers
Continuously reviewing and updating its quality system, objectives and targets in accordance with its ISO9001:2015 certification requirements
Training employees to understand, implement and maintain the company’s quality policy by following documented procedures, processes and policies

Keith Price
Group Operations Support Director
April 2020

Liability insurance

Certificate of Employer’s Liability Insurance

Group Insurance Covers

AACR Professional Indemnity Insurance

Introduction

Andrews Sykes Group PLC takes the privacy of your information very seriously. This policy explains how and for what purposes we use the information collected about you via www.andrews-sykes.com (referred to below as the “Site”). Please read this privacy policy carefully. By using the Site and any services we offer via the Site, you are agreeing to be bound by this policy in respect of the information collected about you via this Site.

If you have any queries about the policy, please get in touch with us using the contact details set out at www.andrews-sykes.com and we will do our best to answer your questions.

Personal information

We will not ask you to supply any personal information, and no personal information will be gathered from your computer when you visit the Site.

If you choose to contact us through a link, form or other facility in the Site we will only retain any e-mail address supplied for the purposes of responding to your enquiry. Your e-mail address will not be passed or supplied to a third party without your express permission unless ordered to by the Courts.

Information automatically collected from your computer

When you visit the Site our web server automatically records your IP address. No personal information about you will be identified from this IP address. We use IP addresses to help us administer the Site and to collect demographic information for aggregation purposes.

We may also gather other non-personal information (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service.

Cookies

When you visit the Site we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and can not be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies for the following purposes:

We use cookies so that you will not have to re-enter your preferences each time you visit the Site

We use cookies to track how our site is used and to improve and update our content

You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but certain parts of the Site may be reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.

Analytics - allow us to monitor how people use the website and optimize our content accordingly to improve user experience
Login settings and preferences - in order for us to remember your preferences after logging in
Remarketing - in order for us to re-advertise to you when you are browsing other websites
Email marketing - in order for us to tailor our email messages to make them more relevant based on how you use the website

Linking to third party websites

We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by sending an e-mail to us at info@andrews-sykes.com or write to us at Andrews Sykes Group PLC, Andrews Sykes Head Office, St David’s Court, Union Street, Wolverhampton, WV1 3JE

Updated April 2020

1. Introduction

The Company is committed to complying with the Bribery Act 2010 whilst operating under the highest standards of ethical conduct and integrity in its business activities in the UK and overseas.

Under the Bribery Act 2010, a bribe is defined as a financial or other type of advantage that is offered or requested with the:

A relevant function or activity includes but is not limited to, public, state or business activities or any activity performed in the course of a person’s employment, or on behalf of another organisation or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

A criminal offence will be committed under the Bribery Act 2010 if:

An employee or associated person acting for, or on behalf of, the organisation offers, promises, gives, requests, receives or agrees to receive bribes; or
An employee or associated person acting for, or on behalf of, the organisation offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of their duties (where local law does not permit or require such influence); and,
The organisation does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

2. Scope of this policy

This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. This policy covers:

The Company will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. The Senior Management are committed to implementing effective measures to prevent, monitor and eliminate bribery.

This is achieved by:

Carrying out a risk assessment to ascertain the risk of bribery;
Undertaking due diligence procedures proportionate to the assessed risk of bribery
Instigating procedures proportionate to that risk;
Having good internal controls and record-keeping;
Securing the commitment of directors, managers and all staff to the prevention and detection of bribery;
Developing a culture in which bribery is unacceptable;
Effectively communicating the anti-bribery policy to all staff;
Training all staff to recognise bribery so that they can avoid it and be alert to possible instances of bribery;
Having clear procedures on what to do should bribery be suspected; and,
Monitoring and reviewing the effectiveness of the bribery procedures and updating them as necessary to ensure that they remain effective.

This policy applies to all employees and officers of the Company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the Company (“associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of the Company.

The Company may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010. All employees and associated persons are required to familiarise themselves and comply with this policy, including any future updates that may be issued from time to time by the Company.

3. What is prohibited?

3.1 Offering bribes

The Company expressly prohibits any person employed by or associated with it from offering, promising or giving any financial advantage or other reward to another person where it is intended that the advantage will bring about improper performance by another person of a relevant function or activity, or that the advantage will reward such improper performance.

The Company prohibits any person employed by or associated with it from offering, promising or giving any financial advantage or other reward to another person where it is believed that the acceptance of the advantage offered, promised or given in itself constitutes the improper performance of a relevant function or activity.

3.2 Accepting bribes

The Company expressly prohibits any person employed by or associated with it from requesting, agreeing to receive or receiving any financial advantage or other reward with the intention that a relevant function should be performed improperly as a result of the advantage or as a reward for performing the relevant function improperly. The improper performance of a relevant function in anticipation of receiving financial advantage or other reward is also prohibited.

3.3 Bribing a public official

The Company expressly prohibits the bribing of a UK or foreign public official in order to obtain or retain business or an advantage in the conduct of business.

3.4 Relevant functions and activities

Relevant functions and activities are any function of a public nature, any activity connected with the business, any activity performed in the course of a person’s employment and activity performed by or on behalf of a body of persons where the person performing that function or activity is expected to perform it impartially, in good faith, or is in a position of trust by virtue of performing it.

3.5 Hospitality and business gifts

The Bribery Act 2010 does not seek to prohibit reasonable and proportionate hospitality, gratuities, advertising, sponsorship and promotional or other similar business expenditure, as it is recognised that this constitutes an established and important part of doing business. However, hospitality, promotional and similar business expenditure can be used as bribes. The Company expressly prohibits the giving and receiving of hospitality/business gifts and similar whenever these could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide expenditures. The following procedures should be adopted in relation to hospitality and business gifts:

All offers of business gifts exceeding £40/€50 in value should be referred to a senior manager and should only be accepted if clearance has been granted.
Business gifts exceeding £40/€50 in value should not be made without the permission of a senior manager. The provision of small Company branded promotional gifts, such as diaries, pens or similar, will generally be regarded as acceptable.
All business gifts made and the reason for the gift must be identified on the relevant expenses form and authorised by a senior manager.
All employees must declare hospitality, benefits or gifts received from third parties during the course of their employment.
All hospitality must be proportionate and reasonable and in line with the Company's hospitality policy. Guidance should be sought from a senior manager as to whether the planned hospitality is proportionate and reasonable.
Records should be maintained of all hospitality provided and accepted, including cost and reason for providing or accepting the hospitality.
Quid pro quo arrangements are expressly prohibited.
Cash gifts are expressly prohibited.
The provision or acceptance of entertainment of a sexual nature is expressly prohibited.
Acceptable hospitality and entertaining may include modest meals with people with whom we do business (such as providing a modest lunch after a meeting) or the occasional provision of or attendance at sporting or cultural events, provided that the intention is to build business relationships rather than to receive or confer an advantage.
Staff reviewing expense claims should be alert to the provision of hospitality/business gifts that may be construed as a bribe.
All concerns should be reported to the Anti-Bribery Committee.

3.6 New business, change in business and contracts with external parties

Where you develop or seek to develop new avenues for business or new contracts, or where the nature of the business changes, you should inform your line manager of this in order that due diligence and a risk assessment of the circumstances can be undertaken.

Where a business relationship with an external party is sought or newly established, or the nature of the relationship is changed, appropriate due diligence must be exercised to ensure that there are no circumstances giving rise to a concern. That external party must also be made aware of this antibribery policy.

3.7 Facilitation payments

Facilitation payments are small bribes that are paid to speed up or facilitate government action. Although they are commonplace in some foreign countries, they are regarded as bribes and are illegal under the Bribery Act 2010. The Company expressly prohibits facilitation payments of any sort. Any member of staff placed under pressure to make a facilitation payment should refer the matter to a senior manager immediately or report their concern to the Anti-Bribery Committee.

3.8 Donations

The Company expressly prohibits the giving of donations to political parties. Any charitable donation must be consistent with the Company’s policy on charitable giving and with the knowledge and consent of a senior manager. The Company expressly prohibits the making of charitable donations where the purpose of the donation is to secure an advantage. All charitable donations must be made without expectation of reward.

4. Working Overseas

Employees and associated persons conducting business on behalf of the Company outside the UK may be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees.

Employees and associated persons owe a duty to the Company to be extra vigilant when conducting international business, as the provisions of the Bribery Act and this policy still applies even if the offence is committed overseas.

Employees and associated persons are required to cooperate with the Company’s risk management procedures and to report suspicions of bribery. While any suspicious circumstances should be reported, employees and associated persons are required particularly to report:

Close family, personal or business ties that a prospective agent, representative or jointventure partner may have with government or corporate officials, directors or employees;quired particularly to report:
A history of corruption in the country in which the business is being undertaken;
Requests for cash payments;
Requests for unusual payment arrangements, for example via a third party;
Requests for reimbursements of unsubstantiated or unusual expenses; or
A lack of standard invoices and proper financial practices.

If an employee or associated person is in any doubt as to whether or not a potential act constitutes bribery, the matter should be referred to the antibriberyconcerns@andrews-sykes.com.

5. Records

Employees and, where applicable, associated persons, are required to take particular care to ensure that all Company records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials. Due diligence should be undertaken by employees and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative in accordance with the Company’s procurement and risk management procedures.

Employees and associated persons are required to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered.

6. Communication and Training

The Company will regularly communicate its anti-bribery measures to employees and associated persons. The Company will set up training sessions where applicable. The Anti-Bribery Committee is responsible for the implementation of this policy.

7. Monitoring and Reviewing

The Anti-Bribery Committee will monitor and review the implementation of this policy and related procedures on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts and entertainment policies.

Employees and those working for, or on behalf of, the Company are encouraged to contact antibriberyconcerns@andrews-sykes.com with any suggestions, comments or feedback that they may have on how these procedures may be improved.

The Company reserves the right to amend and update this policy as required. For the avoidance of doubt, this policy does not form part of employees’ contracts of employment.

8. Reporting concerns

All members of staff have a responsibility to prevent, detect and report all instances of bribery. Staff should therefore be alert to the possibility of bribery. Anyone who has concerns regarding acts or potential acts of bribery should email their concerns to antibriberyconcerns@andrews-sykes.com. If email is not available, staff may write to the Anti-Bribery Committee c/o Andrews Sykes Group, St David’s Court, Union Street, Wolverhampton WV1 3JE. Where possible, reports will be treated in confidence.

The Company will investigate any potential breach in accordance with the disciplinary policy. The ultimate sanction for a breach of the policy will be summary dismissal for gross misconduct.

Updated March 2022

Under Section 78 of the Equality Act 2010 UK companies that employ more than 250 people are required to report the gender pay gap within their workforce. The intention behind gender pay gap reporting is to increase transparency of the differences in earnings between men and women with the aim of closing the gap. Andrews Sykes Group plc has a number of subsidiaries of which only one – Andrews Sykes Hire Ltd – employs more than 250 people in the UK. Below we set out and explain the Andrews Sykes Hire Ltd gender pay gap.

WHAT IS A GENDER PAY GAP?

Gender pay gap data gives a high-level indicator of women’s and men’s relative earning power by showing the difference between women’s and men’s average hourly earnings. The figures published do not explain the underlying causes of gender pay inequality. The gender pay gap is different to equal pay and the two should not be confused.

WHY IS THERE A GENDER PAY GAP IN ANDREWS SYKES HIRE LTD?

The main two reasons for the gap are because our workforce is male dominated. In addition, most of our senior roles are currently filled by men. These reasons are not unique to us as they are common issues across the construction, rental and infrastructure industries.

Our gender pay gap is not because we pay women differently to men for the same work, but because we have women and men in our Company working in different roles which have different salaries.

WHAT ARE WE DOING TO CLOSE THE GENDER GAP?

We are committed to doing everything we can to reduce our gender pay gap and there is no one solution to resolve this issue, so we are addressing it in several ways.

Since reporting last year, we have seen a considerable reduction in our gender pay gap results for mean average (reduction by 4%) and medium average (reduction of over 7%) and we are looking at working towards reducing this further over the coming year.

In addition to the above we have seen a significant reduction in the Bonus gender pay gap as a mean average, made to both male and female employees.

As the Company continues to grow, we are continuing to regularly review our recruitment process to improve on how we can attract more talented people to come and join us and start a fulfilling and satisfying career journey with the Andrews Sykes Group.

Part of our growth strategy is to make Andrews Sykes Hire Ltd a place which attracts more women into the industry, and where they can be confident that they will be supported in developing their careers.

This year we are planning on doubling our number of Apprentices across the Company, providing them with an ongoing career path on the successful completion of their Apprenticeships.

We are still on target to reach our goal of 20% of our managerial roles being filled by female employees by the end of 2022. This will be done by recruiting new employees, and by developing and promoting existing female employees within the business. Already this year we have taken on females in what were historically male populated roles.

The HR team at Andrews Sykes Hire Ltd are reviewing how the Company goes about attracting a more diverse range of talent to the business, how we induct people, and how we train and support them throughout their career with the Company. We want all our processes to be fair and equitable, which also means that they work for all genders. We are proud to be an equal opportunities employer.

WHAT IS THE GENDER PAY GAP IN ANDREWS SYKES HIRE LTD?

There are six gender pay gap calculations:

1. Gender pay gap as a mean average 18% (The average hourly pay of females is 18% less than the average hourly pay of males.)

2. Gender pay gap as a median average 12.5% (The median hourly pay of females is 12.5% less than the median hourly pay of males.)

3. Bonus gender pay gap as a mean average 24.5% (The average bonus paid to females is 24.5% less than the average bonus paid to males.)

4. Bonus gender pay gap as a median average – 30.8% (The median bonus paid to females is 30.8% more than the median bonus paid to males.)

5. Proportion of males receiving a bonus payment and proportion of females receiving a bonus payment.

Male	Female
57.9%	57.8%

6. Proportion of males and females when divided into four groups ordered from lowest to highest pay.

	Male	Female
Lower Quartile	75.3%	24.7%
Lower Middle Quartile	91.4%	8.6%
Upper Middle Quartile	82.7%	17.3%
Upper Quartile	95.0%	5.0%

This data has been calculated according to the requirements of the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

Carl Webb
Managing Director

1) WHAT DO THE DIFFERENT STATISTICS MEAN?

“Mean” means arithmetic average of a population so the “mean gender pay gap” is the average, high-level, overall difference between the remuneration of men and women across UK Hire.

“Median” means the middle point of a population. Mean and median gender pay gaps can vary, even though they are calculated from the same sets of data. Each one has advantages and disadvantages.

“Gender bonus gaps” to better understand a gender pay gap, employers must calculate gender bonus gaps. External research shows that, in business in general, men are more likely than women to get a bonus across all management levels.

“Quartiles” identifying the proportion of men and women in four quartiles. Quartiles divide a list of numbers into four groups. Each employee’s hourly pay is ordered from lowest to highest, then divided into four equal groups. The first group – the lower quartile – is the lowest 25% of earners and the last group – the upper quartile – is the highest 25% of earners. This gives a sense of where male and female employees are in the pay hierarchy. If women are concentrated in your lower pay quartiles, it could be contributing towards the gender pay gap.

2) WHAT IS THE DIFFERENCE BETWEEN THE GENDER PAY GAP AND EQUAL PAY?

The intention behind equal pay is to ensure that men and women are not paid differently for doing the same or similar work. This, on its own, does not prevent a gender pay gap. For example, if the majority of women are employed in lower-paid jobs there would be a gender pay gap.

Corporate Social Responsibility

1. Purpose

The Andrews Sykes Group believes that Corporate Social Responsibility is integral to our business.

We are dedicated in ensuring that we conduct our business in an ethical way, taking account of our impact environmentally, economically, socially and in terms of human rights. In addition, this includes our social partners such as local communities, and global responsibilities such as protecting the environment and ensuring our overseas suppliers operate good labour standards. The following key strategies are business led and demonstrate how this policy is implemented.

2. Our People

The development of our people is considered a strategic investment in our business. We are committed to the development of knowledge and skills for all our employees, with an aim to drive customer service, operational excellence and succession planning. An engaged workforce provides the basis for excellent customer service and enhanced customer satisfaction. Communication and recognition ensure that we provide the ideal workplace for our employees. We value our employees’ opinions and seek to actively involve them, where possible, in the decision-making process. We offer flexible working where practicable to help our employees to achieve a work-life balance and are committed in providing fair pay and conditions to all our employees.

3. Induction Process

All employees are informed of the Company’s approach to Corporate Social Responsibility and the environment during the induction process. Line managers are responsible for ensuring that this has happened, and that employees have understood all aspects of Company’s ethical stance.

4. Training

All Managers receive training on the Company’s Corporate Social Responsibility and the environment and how this has an impact on the activities carried out within the organisation. Managers are responsible for communicating this to their employees.

5. Health, Safety and Welfare

The Company is committed in ensuring the health, safety and welfare of all employees and others who may be affected by our activities, The Company complies with all relevant legislation, preventing injury and ill health and to continuously improve the performance of our Occupational Health and Safety Management system, and is accredited to ISO 45001:2018.

The Company is committed to reducing, so far as is reasonably practicable, the risks associated with all our operations and will not compromise health and safety for other objectives. The only way that this can be achieved is for every employee, in whatever capacity, to take reasonable care for the health and safety of themselves and others who may be affected by their activities. This is done by providing our employees with sufficient information, instruction, supervision and training and involving workers and encouraging the participation of all our employees on matters affecting their health, safety and welfare.

6. Our Business Ethics

Our policy is to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and as a Company we are committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever we operate.

The Board and Senior Management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery and corruption, in accordance with the Bribery Act 2010. We also expect our business partners, especially those introducing business to the Company, to promote and follow its policy or equivalent policies of their own. We will not do business with third parties which fail to demonstrate that they conduct business in a manner which is consistent with our Anti-Bribery and Corruption Policy.

7. Our Environment

The Andrews Sykes Group aims to sustain and improve the natural environment for the benefit of all.

We recognise our responsibility to the environment, our duty to prevent pollution and to comply with all relevant legislation and other requirements applicable to our operations. We are committed to maintaining a certificated Environmental Management System that meets the requirements of ISO 14001:2015. Objectives and Targets are established to reduce to a minimum, any adverse effects we have on the environment and to continuously improve our environmental performance.

The Andrews Sykes Group encourages all employees to participate in activities that aim to minimise the company’s environmental impact. Environmental awareness training is provided to new employees. We communicate regularly with our stakeholders, including shareholders, employees and customers on matters of environmental policy and practices. We also encourage suppliers to adopt the highest environmental standards.

The Andrews Sykes Group has met the UK mandatory requirements of the Energy Savings Opportunity Scheme (ESOS), and has certification to the ISO ISO9001:2015, and CEMARS (in accordance to ISO 14064-1: 2006) standards. In the UAE, the Group has certification to ISO ISO9001:2015 and ISO 14001:2015.

8. Quality

It is the policy of the Andrews Sykes Group to provide products and services that fully and consistently meet the requirements of our customers, both now and in the future. We are committed to maintaining a certificated Quality Management System that meets the requirements of ISO ISO9001:2015.

Objectives and Targets are established to enhance customer satisfaction through the constant improvement of our systems and processes.

Our aim is for continual improvement of the effectiveness of our Management Systems through Management Reviews and we are committed to providing adequate resources to achieve this objective.

9. Sustainability

Over the years, the investment in our hire fleet has been focused on sustainable sourcing with environmental impact kept to a minimum. Our aim is to have products that are best in class for performance, energy consumption with minimum noise pollution and high levels of recyclability.

10. Our Communities

The Andrews Sykes Group is an active member of the communities in which it operates within, and constantly aims to be a good neighbour within the community.

We make a positive contribution to local communities by bringing jobs for local people. We also sponsor local causes and encourage our employees to become involved in fundraising and charitable activities. This is demonstrated with our involvement with the Charlton Athletic Community Trust where, using the power of football, the Trust works in partnership with local communities to empower individuals to improve their lives and environment.

Keith Price
Group Support Operations Director
October 2021

Modern Slavery and Human Trafficking Statement

For FY 2021

Introduction

We are committed to protecting against any form of slavery and human trafficking throughout our business or in our supply chains. This statement sets out the steps we have taken since FY 2016 both within our business and to monitor compliance by our suppliers.

Organisational structure and activities

We are one of the market leaders in the rental of Pumping equipment and Specialist Climate Control products which include Air Conditioning and Chillers, Heating and Boilers, Dehumidifiers and Ventilation. Our products and services are supplied throughout the UK, Europe, and the Middle East via a network of depots.

Supply chains and due diligence processes

Our supply chains are in the UK, Europe, the Middle East, and Asia. As part of our initiative to identify and mitigate risk, we asked our top suppliers to complete a questionnaire to assess the risk in their businesses and we continue to roll this out more widely in our supply chain. The supplier questionnaire includes questions on geographic locations of employment sites, audit of suppliers and training for supplier’s employees. We continue to strive to ensure that our supply chain operates ethically and in the event that any supplier is deemed not to we will reconsider our future relationships with those suppliers.

Policies

Over the course of FY 2016, we introduced our internal Anti-Slavery and Human Trafficking Policy which we communicated to all staff. We also updated our Code of Ethics which cross-refers to our Anti-Slavery and Human Trafficking Policy and other policies, including our Whistleblowing Policy. Our Anti-Slavery and Human Trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our Board of Directors has overall responsibility for ensuring compliance with this policy, and management at all levels ensure those reporting to them understand and comply with this policy on an ongoing basis.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we have provided a training programme to certain staff which includes a knowledge assessment, which we are rolling out in the key business areas, particularly Procurement. Key staff will continue with refresher training on an annual basis.

Other steps

We have reviewed the basis upon which we contract with our suppliers, via written agreements and terms and conditions, to ensure that we can terminate supplier arrangements if we suspect any breach of the Modern Slavery Act or other legislation.

We recognise the importance of the Modern Slavery Act and are committed to reviewing and assessing risks in our supply chain in order to prevent and mitigate any actual or potential impacts. Over the course of the next financial year, we will continue with our training programme and supplier due diligence to ensure continued compliance.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Andrews Sykes Group and Andrews Sykes Hire Limited Modern Slavery statement for the financial year ending 31 December 2021. This statement has been approved by the Board of Directors and signed on behalf of the Board by Carl Webb, the Group Managing Director.

Carl Webb
Managing Director
April 2022