Introduction

The purpose of this policy is to clearly set out how Via East Midlands Limited (hereafter Via) will ensure modern slavery and ethical labour are embedded throughout its business, including its supply chains for the financial year ending 31st March 2025.

Via’s policy is to conduct its business in an honest, open, and ethical manner and to act professionally, fairly and with the utmost integrity in all our business dealings. Accordingly, Via takes a zero-tolerance approach to modern slavery and human trafficking and aims to ensure that its supply chains and every part of its business are, and remain, free from slavery and human trafficking.

This statement has been approved and signed by Dan Maher, Managing Director.

Organisational Structure and Supply Chains

Via East Midlands Ltd. Via is a highway design, construction, maintenance, and management company that is wholly owned by Nottinghamshire County Council. Via operates within the East Midlands region of the UK, with no operations outside of the UK.

We are a major employer in Nottinghamshire, with a multi-skilled, local workforce and a range of highly trained staff based at a number of different locations throughout the county. As an organisation, we support the implementation of the Modern Slavery Act 2015 and are committed to treating people fairly and this includes preventing slavery and human trafficking within our business and supply chains. We pay all of our employees at least the Living Wage Foundation’s Living Wage to ensure none of our employees are in poverty.

Where relevant and appropriate, we already seek approval from our supply chain through tendering processes that safeguarding arrangements are in place.  All suppliers must adhere to the Modern slavery act 2015.  In addition, we are encouraging our supply chain to register with the government modern slavery assessment tool MSAT (Modern Slavery Assessment Tool – Supplier Registration Service (cabinetoffice.gov.uk).  By using MSAT this allows Via to work in partnership with suppliers to improve protections and reduce the risk of exploitation of workers in our supply chains.

Relevant Policies

Via carries out a number of relevant activities under this statement:

  • Safeguarding Policy – Via works directly with schools in Nottinghamshire, and also as a direct provider of apprenticeship training., We have robust safeguarding policies in place, and these incorporate our responsibilities around modern slavery. Via’s Safeguarding Committee are responsible for monitoring the modern slavery agenda within Via and ensuring it is embedded appropriately.
  • Recruitment Policy – We comply with the Asylum, Immigration and Nationality Act 2006 for all new employees. Evidence of eligibility to work in the U.K. must be provided prior to commencing work with Via and where evidence cannot be supplied, offers of employment will be withdrawn. Robust checks and monitoring for new employees are conducted prior to an employee commencing employment within Via.
  • Whistleblowing Policy – We encourage all our workers, customers and other business partners to report any concerns related to the direct activities or the supply chains of the business. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
  • Dignity at Work – This policy makes clear to employees the actions and behaviour expected of them when representing our organisation.

In addition to Via’s own policires , using its position in relation to its relationship through frameworks and other partnerships, Via will support all partners in their respective efforts to identify and address any modern slavery and ethical labour issues identified within programmes of work within those frameworks.

Via is committed to working alongside its suppliers and partners to tackle any issues of modern slavery or labour exploitation, along with working alongside the appropriate regulatory and law enforcement partners where appropriate.

Raising Awareness and Training:

Via will.

  • Define the standards and behaviours Via expects of its organisation and its people, in the way in which the services offered by Via are planned, managed and delivered;
  • Take steps to understand and mitigate for risks within its own supply chain;
  • Ensure that all employees understand Via’s modern slavery and ethical labour policy and priorities, and how the policy is relevant to their day to day work;
  • Articulate why modern slavery and labour exploitation is important to Via and how it adds real benefit to the communities Via serves, setting out its commitments;
  • Establish a position of thought leadership in respect of modern slavery and ethical labour outcomes, helping to change attitudes and behaviours in everyone engaged in the built environment;
  • Set out expectations of its framework delivery partners and their supply chains as new frameworks are procured and collaborative relationships for delivering public services are entered into.
  • Seek opportunities to promote a broader understanding of modern slavery and labour exploitation within its sphere of influence;
  • Collaborate with appropriate organisations to promote these issues in a manner which is consistent with the role of the business; and

Due diligence

As for our contractor supply chains, we conduct due diligence on all our contractors and suppliers as part of our tendering exercises.

Furthermore, Via’s framework procurements are governed by the Public Contracts Regulations 2015. Our assessment of a bidder’s response considers the information they provide in respect of compliance and the procedures they have in place to meet the requirements under the MSA.

Our CIPS registered Procurement Team have completed training in ethical procurement and supply.

Policy Responsibilities

The Managing Director is responsible for the company’s compliance with the Anti-Slavery and Human Trafficking Statement and for ensuring that the policy is reviewed periodically .

The Via Senior Leadership Team is responsible for ensuring this policy is implemented and that systems and processes are developed and monitored.

All line managers are responsible for ensuring that all employees are aware of their responsibilities under the Policy and that it is fully implemented throughout their department.

All staff (including employees, volunteers, contractors and consultants) have a responsibility to comply with this policy.

Daniel Maher
Managing Director