Modern Slavery Statement
Modern Slavery and Human Trafficking Statement for the financial year ended
31 December 2022
This statement is made by John Laing Group Limited (“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.
It continues to be our priority to ensure that we trade ethically, source
responsibly and work to prevent modern slavery and human trafficking
throughout our organisation and in our supply chain.
We report each year on a number of matters such as policy, training, and
due diligence processes 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
John Laing is a leading international investor and active manager of core
infrastructure assets. We invest across the spectrum of development, in
construction, and already operational assets, and across a range of sectors,
including transportation, energy and utilities, telecommunications and social
John Laing has successfully delivered more than 150 infrastructure assets
across the UK & Europe, North America, Australia, New Zealand and
We are also signatories to the UN Principles for Responsible Investment
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.
The Board of John Laing is responsible for matters of corporate
responsibility, including the issues of modern slavery and human trafficking.
We have appropriate policies in place that underpin our commitment to
ensure that there is no modern slavery or human trafficking in our supply
chains or in any part of our business. We continuously review and update all
We also have a governance framework which includes a number of
executive committees which are responsible for maintaining the project
controls compliance framework to ensure that existing assets and potential
new investments and associated partners are screened and subject to
appropriate due diligence in relation to their approach to labour and working
Our Anti-slavery 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.
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 Board is 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. In addition to this confirmation, the John
Laing Group carries out desktop due diligence and where appropriate,
enhanced due diligence, on its suppliers and transaction counterparties,
which include searches for adverse news, criminal and high-risk activities.
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.
Monitoring and Review
We will continue to monitor our supply chain and investment portfolio in
relation to slavery and human trafficking via our control mechanisms.
We provide training to all our staff, including those members of staff who
manage supplier relationships or manage any businesses where we
consider there to be a risk of slavery.
The John Laing Board of Directors is committed to implementing and
enforcing systems and controls to safeguard against modern slavery, human
trafficking and harmful working practices.
Chief Operations Officer and General Counsel