This is the Modern Slavery and Human Trafficking Statement of the Breedon Group of companies (“the Breedon Group”) for the 12 months ending on 31 December 2019 being the same date on which the Breedon Group’s financial year ended.
Whilst the Modern Slavery Act 2015 (“the Act”) does not apply to all jurisdictions in which the Breedon Group operates, we are committed to the spirit of the Act and expects all companies to comply with it. For the purposes of compliance with the Act this Statement covers the following companies within the Breedon Group: Breedon Cement Limited (CRN 08284549), Breedon Southern Limited (CRN 00156531), Breedon Northern Limited (CRN SC144788) and Whitemountain Quarries Ltd (CRN NI018140).
Under section 54 of the Act, organisations with a turnover in excess of £36 million must produce a slavery and human trafficking statement setting out the steps an organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business.
The report should as a minimum set out the following:
- the organisation’s structure, its business and its supply chains;
- the organisation’s policies in relation to slavery and human trafficking;
- its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
- the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
- its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; and
- the training related to slavery and human trafficking available to its staff.
Our business, structure and supply chains
The Breedon Group is the largest independent construction materials company in the UK and Ireland.
The Group manufactures and sells for resale or consumption into the UK and Irish market, the following: cement, aggregates (including decorative aggregates), asphalt, ready-mixed concrete, concrete products and mortar. The Group also operates contract surfacing businesses in Northern Ireland, the Republic of Ireland, central England and throughout Scotland.
We operate as five autonomous businesses within the UK and Ireland. Breedon Southern Limited and Breedon Northern Limited are both fully-integrated aggregates businesses with extensive networks of quarries, ready-mixed concrete and asphalt plants and well-established contract surfacing operations. Breedon Cement operates from two cement plants, one in the UK (being the largest independent producer of cement and one in the Republic of Ireland (one of the most modern in Europe). It also imports and exports cementitious products through four dedicated terminals in the UK and Ireland.
Whitemountain comprises all of Breedon’s construction materials and contracting business in Northern Ireland, with specific project delivery in the UK. It also has a bitumen import and distribution business from its terminal at the Port of Belfast. Whitemountain also exports aggregates from its terminal at the Port of Belfast.
Lagan is the trading name for various Irish registered companies which comprises all of Breedon’s construction materials and contract surfacing operations in Ireland. It also has a bitumen import and distribution from its terminal at the Port of Dublin.
We categorise our suppliers as follows:
Direct: these are the suppliers of raw materials without which we could not produce our products and principally include: aggregates, bitumen cement, fuel (including electricity), admixtures and extenders;
Indirect: these are the suppliers and providers of goods, services and facilities which assist in the operation of our business and include: labour, haulage services, operating equipment and other operating services; and
Capital: these are the suppliers of capital items which we purchase for our business, including: fixed and mobile plant, buildings and other operating machinery.
The areas which we source goods and services is predominantly from within the UK, but also from the Republic of Ireland. Some imported cementitious products and specialist capital items are sourced from elsewhere in Europe. Bitumen is purchased and resold through Whitemountain and Lagan, and the raw materials are sourced in Europe.
The Breedon Group is opposed to slavery and human trafficking wherever it might occur, and we have a number of policies in place to mitigate and manage the risk of such practices occurring in any of our businesses or our supply chain irrespective of the jurisdiction in which they operate.
We manage our people openly, honestly and fairly and aim always to behave as a responsible employer, adopting values and standards designed to help guide our staff in their conduct and business relationships. We are committed to having a fully trained and competent workforce and actively promote vocational training for our employees.
We have a whistleblowing policy, which is available to all employees, and includes access to a confidential anonymous telephone contact number, the results of which are sent directly to the Group Services Director and, if appropriate, the Group Chief Executive, through which colleagues can raise any concerns.
Senior employees within the business are made aware of, and expected to comply with, our anti-bribery and integrity policy, and compliance is reviewed regularly.
Our policies and codes of conduct are designed to reduce the impact of our operations on our employees and on the communities in which we operate. To this end, we particularly encourage equal opportunity and a positive approach to health & safety and care for the environment; we see our policies in these areas as an integral part of our business activities. For example, we aim to continuously improve our safety performance and we are steadily increasing the number of sites with environmental, safety and quality certification. During 2019, we appointed a Group Head of Health and Safety, reporting directly to our Group Chief Executive, who will develop and implement a group wide approach to health and safety. We also continue to actively engage with the communities in which we operate through local liaison committees and support for local events, community groups and sports teams.
Our due diligence process
We aim whenever possible to work with preferred suppliers, who we can trust and with whom we can communicate effectively, especially on new areas of law which they may not be familiar with. All key supplier relationships are reviewed regularly.
During 2018 we developed a new supplier process and procedures which is now being utilised by Breedon Cement Limited, Breedon Southern Limited and Breedon Northern Limited. In 2019 we considered how we could make this process Group wide but real progress has been impacted by a number of factors, not least that Lagan and Whitemountain are as yet still not on the same IT platform as the remainder of the Group. We will continue to consider this process in 2020. We have, however, redrafted our standard purchase terms applicable to Whitemountain and Lagan and drafted new subcontractor agreements which each contain an obligation to comply with, inter alia, the Act, relevant anti bribery and competition laws, and our Supplier Code of Conduct.
Assessing and Managing the Risk
As noted above, the vast majority of our supply chain is within the UK and Ireland.
We recognise that some areas pose more of a risk of modern-slavery-related activities than others. This year we are continuing to put in place processes to identify the risks which may exist in our supply chain.
We will try, wherever possible, to procure all our goods and services through our standard purchase terms which impose contractual obligations on suppliers to comply with modern slavery principles, and with all relevant laws.
We constantly challenge ourselves to engage with all our internal and external stakeholders to raise awareness of modern slavery and human trafficking.
Managing and Measuring Effectiveness
During 2019 the Breedon Group had the challenge of integrating its largest acquisition to date and extending its operating jurisdiction into Northern Ireland and the Republic of Ireland. In 2019 we have rolled out a suite of policies and practices which seek to ensure consistent behaviour among our colleagues, in relation to this and other relevant areas.
We continue to try and develop ways of measuring our effectiveness once we have established a uniform system (as far as it is appropriate to do so) for the sourcing of goods and services.
All colleagues with procurement responsibilities are aware of the basic requirements of the Act.
All relevant employees are expected to comply with our anti-bribery and competition law policies, which have been updated again in 2019 and followed up with an extensive training programme. Further training across all businesses (including those in Northern Ireland and the Republic of Ireland) has been delivered during 2019 and will continue into 2020.
In 2019 we produced and distributed an internal guidance note to all senior managers across the enlarged Group highlighting the specific modern slavery risks in the construction industry and identifying potential ways to spot them and report them.
We have used a range of communications channels, from our intranet and our employee magazine together with the “Visible Felt Leadership” programme to raise internal awareness more generally of modern slavery.
We intend to appoint a new Group Head of Sustainability in 2020 whose role will include addressing modern slavery issues across the Group.
As a member of the Global Cement and Concrete Association (GCCA) we will comply with the GCCA’s Sustainability Charter which will include publishing a Code of Conduct incorporating the principles of internationally proclaimed human rights.
In 2020 we will also consider the role of our logistics and operational teams and how they can support us in raising further awareness of the Act and modern slavery on the various sites which we visit.
The Breedon Group will review, update and publish this Modern Slavery and Human Trafficking Statement annually.
Approved on 10 March 2020 by the Board of Directors of Breedon Group plc and signed for and on behalf of the Board.
Group Chief Executive
10 March 2020
Modern Slavery Statement 2019
Modern Slavery Statement 2018
Modern Slavery Statement 2017