Modern Slavery and Human Trafficking Statement
Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2020
This statement is made by John Laing Group plc (“John Laing”) pursuant to Section 54 of the Modern Slavery Act 2015 and applies to all of John Laing’s subsidiaries whether incorporated within or outside the UK. It has been approved by the John Laing Board of Directors.
We will report each year on a number of matters such as policy, training, due diligence processes and the effectiveness of measures taken to combat slavery and trafficking, to drive transparency and promote ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking.
John Laing is a leading international investor across a range of infrastructure sectors. We seek to deliver attractive and sustainable returns over the medium-term. We are a responsible investor, committed to delivering critical and enduring infrastructure which responds to public needs and improves the lives of the communities we serve.
John Laing has operations in seven countries around the world, and invests in the UK & Europe, North America, Latin America and Australia. We invest in greenfield projects and in businesses which develop and own infrastructure assets. We have invested in over 150 projects and businesses to date, across a range of sectors, including transport, social infrastructure, energy transition, accommodation and digital infrastructure.
Work on modern slavery is a part of our ongoing risk management approach to support human rights. The risk of modern slavery within our direct business operations is considered to be low, however John Laing recognises that it can be indirectly exposed to these risks, for example through its supply chain or project relationships.
Modern Slavery and Human Trafficking
The terms “modern slavery” and “human trafficking” have been used as umbrella terms for the acts of recruiting, harbouring, transporting, providing, or obtaining a person for compelled labour or commercial sex acts through the use of force, fraud, or coercion. “Forced or compulsory labour” is defined in Article 2, International Labour Organisation Forced Labour Convention 1930, and “trafficking in persons” is defined in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (the Palermo Protocol).
John Laing recognises that modern slavery is a crime and contrary to fundamental human rights; it is both the business imperative and the moral obligation to carry out its activities in a socially responsible and environmentally sustainable manner, with due consideration given to these human rights. Building on our long history of social awareness and community involvement, John Laing’s aim is to contribute to a sustainable future through our employees, investments, services and business conduct. Our policies can be found on our website, including:
- Equal Opportunities and Fair Treatment,
- Health and Safety, and
- Human Rights.
The Board of John Laing is responsible for matters of corporate responsibility, including the issues of modern slavery and human trafficking. The Board and its Committees review our policies and practices and address any issues which arise. We also have a governance framework which includes a number of executive committees, including an Investment Committee, Management Risk Committee and Portfolio Review & Valuations Committee, which are responsible for ensuring potential new investments and associated partners are screened and subject to appropriate due diligence in relation to their approach to labour and working conditions. We also have a Whistleblowing Policy, and a structured mechanism for individuals to report any wrongdoing, or unethical behaviour, which includes an independent whistleblowing hotline. The Audit & Risk Committee, and Board are made aware of any allegations raised under the Whistleblowing Policy.
The John Laing Group, including the projects and businesses in which we invest, has a large number of suppliers across the jurisdictions in which we operate. As an investor and asset manager, we believe the risk of modern slavery or human trafficking in our supply chains and procurement processes to be low. Helping to ensure we are not indirectly exposed, all new suppliers to John Laing Group, are asked to confirm that their organisation will comply (and take all possible steps to ensure that all their suppliers and subcontractors also comply) with all applicable laws, statutes and regulations related to “forced or compulsory labour”, and that they will not engage (and will take all possible steps to ensure that their suppliers and subcontractors will not engage) in any activity, practice or conduct that would constitute modern slavery. Similar requests are made of the parties involved when we invest in or bid for new projects.
John Laing is committed to transparency and promoting ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. Where we have sufficient influence in projects and businesses, we ensure that they follow our practices and policies, including those on modern slavery and human trafficking. All UK based companies in which we invest with an annual turnover in excess of £36m are required to prepare a Slavery and Human Trafficking Statement.
Monitoring and Review
We will continue to monitor our supply chain and investment portfolio in relation to slavery and human trafficking through regular reviews.
Subsequent to the UK Government announcements in late 2020 to enhance the focus of the UK Modern Slavery Act 2015 and the development of similar regulations in a number of our markets, we are refreshing the implications of our policies and disclosures looking at where further enhancements can be made.
We have recently appointed a new ESG Director who will be working with the team to update our approach along with greater supply chain engagement to ensure our procedures are effective in countering modern slavery and associated human rights and criminal abuse.
To ensure that the risks of modern slavery and human trafficking in our supply chains and our business are understood, we will make training available to those members of staff who manage supplier relationships or manage any businesses where we consider there to be a higher risk of slavery.
Chief Executive Officer