1.0 Introduction
The UK Modern Slavery Act 2015 requires OHMG (Holdings) Ltd. to state the actions they have taken during the financial year to ensure that Modern Slavery is not taking place in their operations or those of their supply chain. OHMG (Holdings) Ltd. are committed to engaging with sub-contractors, supply chain, employees and business partners who can demonstrate they have a zero tolerance approach to Modern Slavery, and a clear understanding of what it entails. We are committed to acting ethically and with integrity in all of our business dealings complying with the Modern Slavery Act 2015, employment and Human Rights. This statement refers to the financial year ending 31st December 2022. It outlines steps taken by OHMG (Holdings) Ltd. to prevent Modern Slavery and Human Trafficking.
OHMG (Holdings) Ltd. first published their Modern Slavery Policy in February 2017, engaging with the values of the UK Modern Slavery Act 2015 has become one of our core company principles; we have strived to focus on the areas of greatest risk.
2.0 2023 Statement
OHMG (Holdings) Ltd. are fully committed to ensuring that all staff and supply chain have an understanding of the risks of Modern Slavery. We fully respect Human Rights in all of our operations and external business dealings. We recognise that Modern Slavery is a crime and a violation of Human Rights and may take many forms: slavery; servitude; forced labour and human trafficking. These violations deprive individuals of their liberty, in order to exploit them for commercial or personal gain. Our core values ensure we take our responsibilities in relation to Human Rights very seriously and therefore we are assured that there is no Modern Slavery in our business, or that of our supply chain. We endeavour to continue monitoring this rigorously, and place it at the forefront of our relationship with our Supply Chain.
3.0 About OHMG (Holdings) Ltd.
OHMG (Holdings) Ltd. are an established main contractor now in their 50th year in business, and have experience in delivering complex construction projects throughout the UK and Ireland. We have an integrated management system accredited to ISO 9001:2015; ISO 14001:2015 and ISO 45001:2018 which helps to deliver each of our contracts safely, on time, within budget and to the required quality standards. OHMG (Holdings) Ltd. are a Chartered Building Company and are members of the following:
- Construction Employers Federation
- Construction Industry Federation
- National House – Building Council
- Construction Line
- Contractors H&S Assessment Scheme
- Home Bond
4.0 Our Supply Chain Management (Risk Assessment & Due Diligence)
OHMG (Holdings) Ltd. manage and control our supply chain by the implementation of our Safety, Health, Environmental, & Quality (SHEQ) Management System, accredited to: ISO 9001:2015, 14001:2015 and ISO 45001:2018. The Procurement Manager selects the supply chain by implementing our accredited evaluation process using a pre-selection questionnaire and weighted matrix. This process includes a commitment from our supply chain to align their Slavery Policy with OHMG (Holdings) Ltd. policy.
The scale of these supply chains, gives us the opportunity to promote respect for Human Rights and to make a positive impact on people’s lives.
5.0 Policies in relation to Modern Slavery
OHMG (Holdings) Ltd. are aware of the following important internationally recognised declarations, standards and codes:
- The UN Universal Declaration of Human Rights
- The UN Guiding Principles on Business and Human Rights
- The UN Global Compact
- The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
- The Base Code of the Ethical Trading Initiative
Our approach to addressing Modern Slavery has been established with consideration of this wider human rights agenda. Our strategy is supported by the following policies:
- Modern Slavery Policy
- CSR Policy
- Equality Policy
- Employee Policy
We investigate all allegations in relation to a breach of our policies and our Construction Directors named in 6.0 below reports any concerns to RightCall.
6.0 Responsibilities for implementation of our Modern Slavery Policy
Construction Directors Cathal O’Hare & Seanie O’Hare are responsible for the implementation of our Modern Slavery Policy.
7.0 Our Progress
OHMG (Holdings) Ltd. are committed to ensuring there is transparency in our approach to tackling Modern Slavery and we expect our sub-contractors, supply chain, employees and business partners to achieve these high standards. During 2023, we have:
- Continued to review and amend the risks of modern slavery within our own business to implement and update effective policies to support Human Rights
- Posters are displayed on all sites to raise awareness of Modern Slavery
- Updated information advising staff and subcontractors with concerns regarding Modern Slavery, has been displayed in bathrooms so any site staff who have concerns can discreetly read/ contact the helpline in private
- We continue to gather information from our Supply Chain via their pre-selection questionnaire to update our approved list of sub-contractors
- Reporting mechanisms – Employees, business partners and suppliers with concerns regarding modern slavery can report them through the following channels;
Independent reporting service: RightCall
Email: rightcall@expolink.co.uk
Website: www.expolink.co.uk/rightlink
Telephone: 0800 915 4043
8.0 Plans for 2024/ 2025
We are committed to continue improving our approach to respecting human rights and preventing modern slavery. In this context, in 2024/2025 we will:
- Continue to assess our supply chain via their pre-selection questionnaire
- Continue providing Modern Slavery training to all employees
- Continue to create posters for all sites to make our employees supply chain more aware of warning signs
- Include a section on Modern Slavery in our Employee Manual and Policy booklet which is given to all new staff members
- Make all staff aware of any new legislation or updates to existing Modern Slavery legislation
This policy has been approved & authorised by Martin Lennon, Managing Director, 19/01/2024
