Modern Slavery Policy

1. Scope

This policy applies to all employees and individuals at all levels and all activities within JN Civils Ltd.

This includes employees, contractors, sub-contractors, partners, supply chain providers or any other person associated or with whom JN Civils Ltd contract with directly or who we appoint to act on our behalf.

2. Policy Statement

JN Civils Ltd is committed to opposing modern slavery in all its forms and preventing by whatever means we can. We expect the same attitude from all our employees, sub-contractors, partners and of all parties with whom we have any kind of business dealings.

As a company, we have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers or clients/business partners.

We expect all employees, sub-contractor and any other organisations or persons who has or seeks to have a business relationship with JN Civils Ltd to familiarise themselves with our anti-slavery policy and to act at all times in a way which is consistent with this policy.

Following the introduction of the Modern Slavery Act 2015, modern slavery can occur in a variety of forms including forced labour, servitude and human trafficking, all of which have a common theme of deprivation of an individual’s liberty by another person or group of people in order to exploit them for personal or commercial gain.

This document sets out our policy with aim of the prevention of opportunities for modern slavery to occur within its business or supply chain.

3. Commitments & Expectations

We are committed to our disclosure obligations under the Modern Slavery Act, 2015 and to ensuring that there is transparency within our own business and in our approach to tackling modern slavery throughout our supply chains.

We expect the same high standards from all of our contractors, sub-contractors, suppliers and all other business partners and we expect our suppliers to hold their own suppliers and partners.

We are committed to evolving and updating our contracting procedures to include specific prohibitions forced, compulsory or trafficked labour, or anyone held in slavery or servitude whether adults or children.

We expect all our employees to familiarise themselves with our policy and procedures to help in the identification and prevention of modern slavery and to conduct business in a manner that ensure the opportunity for and incidence of modern slavery is prevented.

All employees are expected to adhere to this policy, which forms part of all employees’ obligations under their contract of employment.

We are committed to ensuring that modern slavery and human trafficking is not taking place in our supply chain but acknowledges that we cannot control the conduct of individuals and organisations in that supply chain

We will therefore:

• Introduce contractual provisions for our suppliers to confirm their adherence to this policy and acceptance of our right to audit their activities and relationships at times and on a routine basis.
• Make our suppliers aware of their responsibility to adhere to our modern slavery policy to ensure that modern slavery is not occurring in their business activities.
• In instances, where non-compliance is discovered, we are committed to taking appropriate action. We will only trade with those who comply fully with this policy.

4. Reporting Modern Slavery Incidents

Any other person wishing to raise a concern should contact JN Civils Ltd HR Department.

That person should formally raise a concern if:

• They suspect a person acting on behalf of JN Civils Ltd is seeking to exploit another person in a way which could amount to modern slavery.
• They suspect that a person acting on behalf on one of our suppliers is seeking to exploit another person in a way which could amount to modern slavery.
• They have been approached from another person acting on behalf of JN Civils Ltd who has invited them to participate in acts which could result in offence under the Modern Slavery Act, 2015 being committed.

Any concerns in relation to suspected modern slavery associated with the company or our suppliers may be reported by an employee through the Company’s separate “whistle blowing” policy.

The nature of the complaint will then determine the company’s next course of action.

Should they have the information which leads to the rational conclusion that a person acting on behalf of JN Civils Ltd or one of our suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act, 2015.

Any reports of this nature will be kept confidential subject to the need for JN Civils Ltd to act responsibly and within the law, e.g. that our maintaining confidentially of the source of the information is not permitted by law or indeed is not consistent with our procedures to prevent modern slavery being committed on our behalf or within our supply chain.

5. Safeguarding

We aim to encourage openness and will support anyone who raised genuine concerns I good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicions of modern slavery in good faith.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. JN Civils Ltd will take seriously any concerns raised anonymously.

Anonymity does make investigations more difficult so individuals are encouraged to put their names to any allegations if possible but will still fully respect the request for anonymity.

Any claims or allegations made which are found to be malicious will result in disciplinary action being taken against the individual through JN Civils Ltd disciplinary procedure.

Our zero-tolerance approach to modern slavery must be communicated all to suppliers, contractors and business partners at the beginning of our business relationship with them and reinforced as appropriate thereafter.