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Modern Slavery Transparency Statement

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Background

This Transparency Statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (“the Act”).  It constitutes the joint Transparency Statement for Foster Denovo Group Limited and Foster Denovo Limited (together, referred to as “Foster Denovo”), for the financial year ending 31 December 2024.  This Statement was approved by the Boards of Foster Denovo Group Limited and Foster Denovo Limited in June 2025.

Our commitment

We are unconditionally committed to preventing slavery and human trafficking in our business activities, and to ensuring that our supply chains are free from slavery and human trafficking.

As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff, further ensuring our staff feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Supplier risk assessment

Our supply chains are limited, and we procure goods and services from a restricted range of suppliers.  We expect all those in our supply chain to comply with our zero-tolerance approach to slavery and human trafficking.  Foster Denovo expects its suppliers to assume responsibility for ensuring that their supply chain is assessed for risks in these areas and those risks are actively managed. This expectation is contained in contracts we sign with suppliers or tenders for work in relevant departments.

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chain.  To reach this assessment for our supply chain, we categorised our first tier suppliers by the risk evident in the sectors and jurisdictions in which they operate.  The results of our due diligence found that the vast majority of our main suppliers were low risk, with a very small number of medium risk and no high risk suppliers.  For the medium risk suppliers we undertook additional due diligence to verify that these suppliers comply with the Act.

Due Diligence

Foster Denovo undertakes due diligence when considering taking on new suppliers. Where possible, we build long standing relationships with suppliers and make clear our expectations of business behaviour. We have in place systems to encourage the reporting of concerns and the protection of whistleblowers.  We will measure the raising of concerns surrounding slavery and human trafficking to assess the effectiveness of our communications regarding this policy.

We expect each supplier at least, to adopt l one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.

Our policies in relation to the Modern Slavery Act 2015

The following policies are available to all staff through the intranet:

  • Code of conduct
  • Bullying and harassment policy
  • Diversity and inclusion policy
  • Recruitment and selection policy
  • Whistleblowing policy

Reporting a Concern

We operate a Whistleblowing Policy, aimed principally at our employees, self employed partners and workers, but also available to our suppliers that encourages the reporting of any wrongdoing which extends to human rights violations like modern slavery.

We encourage all our employees, volunteers, clients and other business partners to report any concerns related to the direct activities, or the supply chains of Foster Denovo. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation. All reports are fully investigated, and appropriate actions taken.

Embedding the principles

We will continue to embed the principles through:

  • Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
  • Ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
  • Ensuring that consideration of the modern slavery risks and prevention are added to Foster Denovo’s policy review process as an employer and procurer of goods and services
  • Making sure Foster Denovo’s procurement strategies account for modern slavery and human trafficking
  • Continuing to take action to embed a zero-tolerance policy towards modern slavery
  • Ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

 

This statement will be reviewed and updated every year.