This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Rowleys Commercial Energy Assessment Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

The policy’s purpose is to:

• Prevent modern slavery in all its forms.

• Ensure compliance with the Modern Slavery Act 2015 for both ourselves and those that use our services.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Rowleys Commercial Energy Assessment Limited has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

Rowleys Commercial Energy Assessment Limited provides energy efficiency assessments, consultancy and related services throughout the UK. These activities are carried out using a combination of our own employees and carefully selected sub-contractors.

Our high risk areas

The vast majority of our work is conducted by staff directly employed by us and all of our work is conducted within the UK minimising our exposure to modern slavery practices. More vulnerable areas of our business include:

1. Use of sub-contractors: We ensure that our sub-contractors are registered with a government approved Accreditation Scheme (Approved Organisation in Scotland) for the area of work which they are conducting on our behalf. Proof of entitlement to work in the UK is a mandatory part of the registration process. Additionally, we do not use employment agencies, gangmasters or assessment panels to recruit workers or sub-contractors.

2. Supplier purchases: Our business does not involve the processing of materials and so our purchasing is limited to operational services and supplies, the majority of which are of low value and sourced within the UK. Suppliers of high value purchases are actively screened (see below) while all staff engaged in making purchases on behalf of the company have received Modern Slavery awareness training.

Our policies

We operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:

1. The measures established in this Modern Slavery Statement.

2. Our Anti-Bribery Statement (FC17M01) which clearly establishes the organisation’s stance and expectations relating to bribery and questionable incentive practices.

3. Our policy Health & Safety at Work (HS16G01) which clearly establishes the organisation’s stance and expectations relating to the health, safety and welfare of our workers and other affected by our work.

4. Our policy Equality & Diversity (PE16D01) which clearly establishes the organisation’s stance and expectations relating to equal opportunities and challenging discrimination.

5. Robust recruitment practices, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

6. Positive employment practices including ensuring all our employees have written contracts of employment and paying all our employees at least the National Minimum Wage. Additionally, we actively support the personal development of our staff, including providing opportunities for them to further their personal economic prospects by obtaining nationally recognised and professional qualifications.

7. Corporate openness within our family run business. We operate in a manner where all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Our suppliers

Rowleys Commercial Energy Assessment Limited maintains a list of preferred suppliers and sub-contractors. We conduct due diligence on all suppliers before allowing them to become a preferred supplier or sub-contractor.

1. Screening for sub-contractors: We only sub-contract to our preferred sub-contractors. In selecting preferred subcontractors we routinely:

   1. Check the National Register to ensure a current accreditation exists for the services being offered;

   2. Check trading details (e.g. sole trader / registered company) and cross reference these with independent sources (e.g. Companies House);

   3. Review websites, social media pages, reviews and other online sources;

   4. Refer to prior knowledge and experience of our staff, clients and other suppliers; and

   5. Monitor assessments produced to ensure that the work is not further sub-contracted.

2. Screening for high value preferred suppliers: We consider high value suppliers to be those supplying goods and/or services in excess of £1000 in any three month period. As part of our contract with high value suppliers, we require that they confirm to us that:

   1. They have taken steps to eradicate modern slavery within their business;

   2. They hold their own suppliers to account over modern slavery; and

   3. They pay their employees any prevailing minimum wage applicable within their country of operations, including within the UK.

3. Screening for other suppliers: We believe it is unfortunately not practicable for any business to fully screen all suppliers used for low value items. Equally, to restrict the purchase of such items solely to preferred suppliers would potentially prevent many smaller businesses and sole traders from achieving economic independence undermining the understood intentions of the Modern Slavery Act 2015. This could be particularly discriminatory towards small local businesses around our operations in the UK which we actively try to support. As such, we adopt a pragmatic approach to small purchases where, prior to placing orders, we:

   1. Review websites, social media pages, reviews and other online sources;

   2. Refer to prior knowledge and experience of our staff, clients and other suppliers; and

   3. Consider the status, location and reputation of the organisation involved.

Our commitment

Rowleys Commercial Energy Assessment Limited wishes to make it explicitly clear that we would immediately consider terminating our relationship with any organisation should any instances of modern slavery come to light. This would include, but is not limited to, instances where:

1. They fail to pay their employees any prevailing minimum wage applicable within their country of operations, including within the UK;

2. They actively exploit international tax or employment arrangements to avoid paying the prevailing minimum wage in the UK;

3. They operate in a manner which fails to protect the health, safety or welfare of their workers in a manner consistent with the established practices in their country of operations; or

4. They operate in a manner which is inconsistent with the United Nations’ Universal Declaration on Human Rights (UDHR).

Furthermore, as a professional organisation we expect our staff and those working on our behalf to behave in a responsible manner raising any concerns that may arise in the course of their work both internally and with the appropriate authorities where applicable.

Training

We conduct training for our staff so that they understand the signs of modern slavery and what to do if they suspect that it is taking place.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

1. No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified within our business operations; and/or

2. Reports from our employees or workers are received to indicate that modern slavery practices have been identified outside our business operations.

Approval for this statement

This statement was approved by the Board of Directors on 14 August 2017.

This policy is reviewed on an annual basis and is freely available to our customers, suppliers, employees and the general public. It is published on our website with a direct link from our homepage in accordance with best practice established in the Modern Slavery Act 2015.

Peter Rowley
Company Director
14 August 2017