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FRATRES
Conduct & responsibility

Modern Slavery & Human Trafficking Statement

Steps taken to identify and address modern slavery and human trafficking risk in the firm’s operations and supply relationships.
Document reference
FGL-LEG-15
Version date
1 July 2026
Applies to
Fratres Limited

1.Purpose, scope and status of this statement

1.1
This Modern Slavery and Human Trafficking Statement (the Statement) is made by Fratres Limited (the Company, registered in England and Wales) and sets out the steps the Company has taken to identify, assess and address the risk of slavery, servitude, forced or compulsory labour and human trafficking occurring in its own business and in the business and supply relationships through which it works.
1.2
Section 54 of the Modern Slavery Act 2015 requires a commercial organisation carrying on a business, or part of a business, in the United Kingdom, and having an annual turnover at or above the prescribed threshold, to prepare a slavery and human trafficking statement for each financial year. The Company applies the requirements of section 54 in full, and publishes this Statement as a matter of policy, whether or not its turnover in any given financial year brings it within the statutory obligation. Nothing in this Statement is to be read as a representation about the Company’s turnover.
1.3
The Statement addresses each of the areas identified in section 54(5) of the Modern Slavery Act 2015: the Company’s structure, business and supply chains; its relevant policies; its due diligence processes; the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place and the steps taken to assess and manage that risk; its effectiveness in ensuring that slavery and human trafficking are not taking place, measured against appropriate performance indicators; and the training available to its staff.
1.4
The Statement applies to every director, officer, employee, consultant, secondee, contractor, agent and introducer of the Company, in every jurisdiction in which the Company operates, including the United Kingdom and the People’s Republic of Bangladesh. Adherence to it is a condition of engagement.
1.5
The Company has a zero-tolerance position on Modern Slavery. It will not knowingly enter into, advise on, facilitate, introduce or continue to support any project, transaction or relationship in which Modern Slavery is occurring and is not being remedied. That position is absolute and is not subject to commercial override.
1.6
This Statement is written to be accurate rather than reassuring. Where the Company has influence, this Statement says what the Company requires. Where the Company does not have influence, this Statement says so. Clause 11 sets out plainly what an advisory firm can and cannot control.
1.7
The Statement is published on the Company’s website, is accessible from every page of that website, and is submitted to the modern slavery statement registry maintained by the Home Office. It is made in respect of the Company’s most recent financial year and is reviewed, updated and re-approved annually in accordance with clause 16. The version date shown at the head of this document is the date from which the current version applies.

2.Interpretation and definitions

2.1
In this Statement, headings are for convenience only and do not affect construction; the singular includes the plural and the plural the singular; a reference to a statute or statutory instrument includes that instrument as amended, extended, consolidated or re-enacted; and the words “including”, “in particular” and “for example” are illustrative and do not limit the words preceding them. “Must” and “shall” denote a mandatory requirement; “should” denotes the expected approach, from which departure must be recorded and justified.
2.2
The following defined terms are used throughout the Statement.
Board
The board of directors of the Company, which is accountable for this Statement and approves it annually.
Client
Any person or entity that engages the Company, or proposes to engage the Company, to provide advisory, facilitation or project development services.
Counterparty
Any party other than a Client with which the Company deals, or which is material to a Mandate, including local partners, sponsors, joint venture participants, developers, contractors, operators, concessionaires, introducers, agents, professional advisers and the Company’s own suppliers.
Employer Pays Principle
The principle that no Worker should pay for a job, and that the costs of recruitment — including agency fees, medical testing, documentation, visas, permits and transport to the place of work — are borne by the employer and not by the Worker, whether directly, by deduction, by advance or by any other means.
ILO Indicators
The eleven Indicators of Forced Labour published by the International Labour Organization: abuse of vulnerability, deception, restriction of movement, isolation, physical and sexual violence, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions, and excessive overtime.
Mandate
An engagement accepted by the Company for a Client, together with the underlying project, transaction or investment to which the engagement relates.
Modern Slavery
Slavery, servitude and forced or compulsory labour within the meaning of section 1 of the Modern Slavery Act 2015, and human trafficking within the meaning of section 2 of that Act, together with child labour, debt bondage, the exploitation of migrant workers and any other conduct falling within the ILO Indicators.
MSA
The Modern Slavery Act 2015.
Project Supply Chain
The chain of employers, contractors, subcontractors, labour providers, materials suppliers, logistics providers and service providers engaged in the delivery of a project on which the Company advises, whether or not the Company has any contractual relationship with them.
Recruitment Fee
Any fee, charge, cost, deposit, bond, commission or deduction of any kind imposed on or borne by a Worker, or by a Worker’s family, in connection with obtaining, retaining or travelling to employment, however described and by whomever collected.
Red Flag
An observed or reported fact consistent with one or more of the ILO Indicators, or with the presence of Modern Slavery in a workforce or Project Supply Chain, whether or not it is corroborated at the time it is observed.
Responsible Officer
The officer designated by the Board with day-to-day responsibility for the operation of this Statement, for the maintenance of the Company’s modern slavery risk assessment, and for reporting to the Board.
Statement Year
The financial year of the Company in respect of which this Statement is made.
Worker
Any individual performing work in the Company’s operations or in a Project Supply Chain, irrespective of whether that individual is an employee, an agency worker, a daily-rated labourer, a piece-rate worker, a self-employed contractor, an apprentice or a person engaged informally.

3.Legal and standards framework

3.1
The Company is incorporated and registered in England and Wales and is subject to the Companies Act 2006, including the duty of each director under section 172 to have regard to the impact of the Company’s operations on the community and the environment and to the desirability of the Company maintaining a reputation for high standards of business conduct.
3.2
The principal instrument governing this Statement is the MSA, and in particular sections 1 and 2, which create the offences of slavery, servitude and forced or compulsory labour and of human trafficking; section 3, which defines exploitation for those purposes; and section 54, which governs transparency in supply chains. The Company applies the Home Office statutory guidance issued under section 54(9) in preparing and reviewing this Statement.
3.3
The Company also has regard to the following instruments of the law of England and Wales, each of which bears on the identification or prevention of labour exploitation:
  • the Gangmasters (Licensing) Act 2004 and the enforcement functions of the Gangmasters and Labour Abuse Authority;
  • the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, under which it is unlawful to charge a work-seeker a fee for finding work;
  • the Immigration Act 2016, which established the office of the Director of Labour Market Enforcement;
  • the Proceeds of Crime Act 2002, under which the proceeds of forced labour and trafficking constitute criminal property and may give rise to the offences in sections 327 to 329;
  • the Bribery Act 2010, where payments are made to conceal exploitation or to secure the inaction of an official;
  • the Equality Act 2010, where exploitation is accompanied by discrimination on the ground of a protected characteristic;
  • the Public Interest Disclosure Act 1998 and Part IVA of the Employment Rights Act 1996, which protect those who make qualifying disclosures; and
  • the Sanctions and Anti-Money Laundering Act 2018, under which designations may be made in respect of serious human rights violations, including under the Global Human Rights Sanctions Regulations 2020.
3.4
In respect of activity connected with Bangladesh, the Company has regard to Article 34 of the Constitution of the People’s Republic of Bangladesh, which prohibits all forms of forced labour; the Prevention and Suppression of Human Trafficking Act 2012; the Bangladesh Labour Act 2006 and the Bangladesh Labour Rules 2015, including the provisions governing minimum age, working hours, wage payment and contractor labour; the Bangladesh EPZ Labour Act 2019 in respect of activity within export processing zones; and the Overseas Employment and Migrants Act 2013 in respect of the recruitment and placement of migrant workers. The Company recognises the enforcement roles of the Department of Inspection for Factories and Establishments and of the Bureau of Manpower, Employment and Training.
3.5
Where the standard imposed by the law of a jurisdiction in which a Mandate is delivered is more demanding than this Statement, that standard applies. Where it is less demanding, this Statement applies. Compliance with local law is a floor and is never, of itself, a sufficient answer to a Red Flag.
3.6
The Company aligns its approach with the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the core Conventions of the International Labour Organization on forced labour, the abolition of forced labour, minimum age and the worst forms of child labour, and the Dhaka Principles for Migration with Dignity. The Employer Pays Principle is adopted without qualification.
3.7
This Statement is to be read with the Company’s ESG and Responsible Business Policy (FGL-LEG-16), Client Due Diligence and Know Your Customer Standard (FGL-LEG-09), Anti-Bribery and Anti-Corruption Policy (FGL-LEG-10), Sanctions and Export Controls Policy (FGL-LEG-11), and Whistleblowing and Speak-Up Policy (FGL-LEG-14). Where those documents and this Statement address the same subject, the more demanding requirement prevails.

4.Organisational structure and business model

4.1
The Company is a strategic advisory and project facilitation business. It advises international investors, private sector organisations and project sponsors on market entry, structuring, regulatory pathways, partnership development and the origination and delivery of projects in Bangladesh, principally in foreign direct investment, government-backed and public-private partnership projects, mining and natural resources, civil aviation and aerospace, solar and renewable energy, intelligent transport and smart-city systems, transport infrastructure and logistics, ports and strategic development, and technology infrastructure.
4.2
The Company’s own operations consist of professional and advisory work performed by a small, directly engaged workforce of salaried staff, consultants and specialist advisers, supported by office premises, professional services and standard business goods and services. The Company does not manufacture, does not extract, does not construct, does not operate infrastructure assets, and does not supply labour.
4.3
The Company does not act as employer, principal contractor, employment business, labour provider or recruitment intermediary in relation to any project on which it advises, and does not engage, pay, house or direct project labour. It is not licensed under the Gangmasters (Licensing) Act 2004 and does not carry on any activity requiring such a licence.
4.4
The Company’s relationship to Modern Slavery risk is therefore predominantly one of connection and leverage rather than direct causation. The Company can be linked to Modern Slavery through the Clients it accepts, the Counterparties it introduces or endorses, the project structures it recommends, and the Project Supply Chains that form beneath projects it has helped to bring into existence. That linkage is treated as a genuine responsibility and not as a technical exemption.
4.5
The Company’s activity is concentrated in Bangladesh, a jurisdiction with substantial internal and outbound labour migration, extensive use of informal and subcontracted labour in construction and extraction, and documented incidence of debt bondage and child labour in certain sectors. That concentration is the single most significant determinant of the Company’s Modern Slavery risk profile and is the reason this Statement is drawn as widely as it is.

5.Business and supply relationships

5.1
For the purposes of this Statement the Company distinguishes between three categories of relationship, each of which carries a different degree of control and therefore a different set of obligations.
5.2
Category A — the Company’s own operations and direct suppliers.This category comprises the Company’s workforce and the goods and services it purchases directly, including office accommodation and facilities management, cleaning and catering services, security services, information technology hardware and services, travel, printing and corporate services, and professional advisers. Here the Company has direct contractual control and applies the requirements in clauses 9 and 10 in full.
5.3
Category B — Clients and directly engaged Counterparties. This category comprises the Clients that engage the Company and the Counterparties with which the Company deals directly in the course of a Mandate, including local partners, sponsors, introducers, joint venture participants and consortium members. Here the Company has assessment and acceptance control: it decides whether to act, on what terms, and whether to continue.
5.4
Category C — Project Supply Chains.This category comprises the contractors, subcontractors, labour providers, materials suppliers, logistics operators and site service providers engaged in the delivery of a project on which the Company has advised. The Company is rarely in contractual privity with these parties. Here the Company’s instrument is influence: the standards it advises its Clients to require, the contractual provisions it recommends, the questions it insists are asked, and its willingness to withdraw.
5.5
The Company maintains a register of Category A suppliers and of Category B Counterparties, recording for each the goods or services provided, the jurisdictions involved, the labour intensity of the activity, the assessed Modern Slavery risk rating and the date of last review. Category C exposure is recorded at Mandate level under clause 8.
5.6
The Company does not treat the absence of a contract as the absence of a relationship. Where the Company has introduced a Counterparty, has recommended a structure, or is publicly associated with a project, it accepts that it is connected to the conduct of that project’s Project Supply Chain and must act accordingly.

6.Policies in relation to slavery and human trafficking

6.1
The Company maintains the following policy positions, each of which is binding and each of which is capable of enforcement through the Company’s disciplinary and contractual arrangements:
  • (a)no form of slavery, servitude, forced or compulsory labour, human trafficking or child labour is tolerated in the Company’s operations or in any relationship it enters into;
  • (b)no Worker in the Company’s operations, and no Worker in a Project Supply Chain in respect of which the Company has influence, may be required to pay a Recruitment Fee; the Employer Pays Principle applies without exception;
  • (c)no Worker’s passport, national identity card, birth registration certificate, work permit or other original identity or travel document may be retained, confiscated or held as security by any employer, agent or labour provider;
  • (d)no Worker may be subjected to wage withholding, wage deductions imposed as a disciplinary measure, deposit-taking, or advances structured so as to create or perpetuate debt bondage;
  • (e)all work must be freely chosen and all Workers must be free to terminate their employment on reasonable notice and to leave the workplace and any employer-provided accommodation at the end of a shift;
  • (f)no person under the applicable minimum working age may be engaged, and no person under 18 may be engaged in hazardous work, including work in quarries, on demolition and dismantling sites, at height, underground or in confined spaces;
  • (g)working hours, rest days and overtime must comply with applicable law, and overtime must be voluntary and separately compensated;
  • (h)no Worker may be threatened, intimidated, physically or sexually assaulted, or subjected to retaliation for raising a concern, joining a workers’ organisation or engaging in lawful collective bargaining;
  • (i)employer-provided accommodation, transport, water, sanitation and food must be safe, adequate and free of charges that reduce net pay below the applicable legal minimum; and
  • (j)no person may be dismissed, penalised or subjected to any detriment for refusing to participate in, or for reporting, conduct that this Statement prohibits.
6.2
The Company’s ESG and Responsible Business Policy (FGL-LEG-16) establishes the human rights standard applied to Mandates. The Whistleblowing and Speak-Up Policy (FGL-LEG-14) provides the protected channel through which concerns are raised. The Client Due Diligence and Know Your Customer Standard (FGL-LEG-09) provides the mechanism by which Clients and Counterparties are identified, verified and screened, and the grounds on which a relationship must be refused. Modern Slavery concerns are treated as a mandatory escalation under that Standard.
6.3
The Company’s procurement position is that Modern Slavery compliance is a threshold requirement and not a scored criterion. A supplier or Counterparty that cannot meet the requirements of clause 9 is not compared unfavourably against others; it is not engaged.
6.4
These policies are reviewed at least annually and are amended immediately where a change in the law, a finding from an investigation, or a development in the sectors in which the Company operates makes amendment necessary.

7.Risk assessment and the areas of highest risk

7.1
The Company maintains a written Modern Slavery risk assessment covering its own operations, its direct suppliers, its Clients and Counterparties, and the Project Supply Chains associated with each active Mandate. The assessment is reviewed at least annually, on the acceptance of any Mandate in a new sector or geography, and whenever a Red Flag is reported.
7.2
Risk is assessed against sector, geography, workforce profile, contracting structure and the transparency of the labour supply route. The Company assesses the risk in its own operations and among its direct professional suppliers as low, and the risk in Project Supply Chains as high. The following are assessed as the areas of highest risk.
7.3
Construction and civil works.Construction is the Company’s single largest area of exposure. Risk arises from deep and often undocumented tiers of subcontracting; the widespread use of labour-only subcontractors and informal intermediaries who recruit in low-income districts and charge Workers for placement; daily-rated and piece-rate engagement without written contracts; wage advances that function as bonded debt; employer-controlled site accommodation; and the presence of workers whose age and identity have never been independently verified. Risk is concentrated at the point furthest from the principal contractor, which is precisely the point at which conventional supplier audits stop.
7.4
Mining, quarrying and aggregate extraction.Risk arises in stone quarrying and crushing, sand extraction, limestone and hard rock operations and their associated haulage; in the use of seasonal and migrant labour engaged through intermediaries; in hazardous manual work performed without contracts or protective equipment; in the documented incidence of child labour in small-scale extraction and stone breaking; and in artisanal and informal extraction adjacent to licensed concessions, which is frequently outside the licensee’s stated supply chain but not outside its area of influence. Land acquisition and community displacement are treated as aggravating factors, because displaced households are more vulnerable to exploitative recruitment.
7.5
Port, terminal and marine infrastructure labour. Risk arises in dredging, land reclamation, marine civil works, stevedoring and cargo handling, container depot and warehouse operations, and in the ship recycling and vessel dismantling activity carried on in the vicinity of certain port areas, where hazardous manual dismantling, undocumented workforces and the engagement of minors have been extensively documented. Risk also arises in the treatment of seafarers and crew on vessels calling at project facilities, including abandonment and non-payment of wages.
7.6
Infrastructure labour supply and camp services. Risk arises in the recruitment, transport, accommodation and feeding of project workforces: labour supply agents operating without licence or record; the retention of identity documents at camp level; charges for accommodation, transport, food and equipment deducted at source; restrictions on movement in and out of camps; and the engagement of security personnel to control rather than to protect the workforce. Ancillary services — cleaning, catering, laundry, drivers and domestic work — are frequently subcontracted to the least visible providers and are assessed as high risk on that basis.
7.7
Upstream equipment and materials. Risk arises in the manufacture and supply of equipment specified for projects, including upstream polysilicon and photovoltaic module supply chains, in respect of certain producing regions of which credible allegations of state-imposed forced labour have been made; in bricks, tiles and aggregates produced in kilns and yards known to use bonded family labour; in steel, cabling and fabrication; and in textiles and personal protective equipment procured for site use. Traceability in these chains is generally poor and the Company treats an inability to trace as a risk finding rather than as a neutral fact.
7.8
Cross-cutting aggravating factors. The Company treats the following as increasing risk in any of the areas above: internal and cross-border migrant workforces; workers recruited in a language other than that of their contract; the absence of a written contract in a language the Worker reads; the absence of a functioning grievance mechanism accessible to the lowest tier; remote or access-controlled sites; compressed programmes and liquidated damages regimes that transmit schedule pressure downward as wage and hours pressure; and any contracting structure in which the price paid to the lowest tier cannot support lawful wages.
Where the risk actually sits

In the sectors in which the Company works, Modern Slavery is very rarely found at the level of the counterparty a client meets. It is found three or four tiers below, in labour supply, in camp services and in aggregate and materials extraction, where the contracting record thins out and the price per unit of labour stops being capable of supporting a lawful wage. Any risk assessment that stops at the first tier has not begun.

8.Due diligence on counterparties and project supply chains

8.1
Modern Slavery due diligence is not a separate exercise. It is integrated into the Company’s mandate acceptance process, its client and counterparty due diligence under FGL-LEG-09, and its continuing supervision of live Mandates.
8.2
Before a Mandate is accepted, the Company must complete a Modern Slavery screen covering:
  • (a)the sector, the physical works involved, and whether the project will require a manual workforce engaged through intermediaries;
  • (b)the identity, ownership and control of the Client and of every material Counterparty, established in accordance with FGL-LEG-09;
  • (c)adverse media, litigation, regulatory and inspection records concerning the Client and each material Counterparty, searched in English and in Bengali, and expressly including labour, wage, child labour, workplace fatality and trafficking allegations;
  • (d)whether the Client or any material Counterparty, or any person owning or controlling either, is designated under the Global Human Rights Sanctions Regulations 2020 or any other applicable sanctions regime;
  • (e)whether the Client publishes a modern slavery statement, whether it has a human rights policy, and whether its stated commitments are supported by any evidence of implementation;
  • (f)the intended contracting structure, the anticipated depth of subcontracting, and whether the Client has visibility of, or has asserted any control over, the tiers beneath its principal contractor; and
  • (g)the labour supply route: how workers will be recruited, by whom, from where, on what terms, in what accommodation and at whose cost.
8.3
The screen produces a written Modern Slavery risk rating for the Mandate of low, medium or high, recorded with the reasoning that produced it. A rating of high requires the written approval of a member of senior management before the Mandate may be accepted, and that approval must record the risks identified, the measures to be applied and the reasons the residual risk is considered acceptable.
8.4
For every Mandate rated medium or high, the Company must additionally:
  • map the Project Supply Chain as far as the information reasonably obtainable allows, identifying at minimum the principal contractor, each first-tier subcontractor, every labour provider and every camp and transport service provider, and recording expressly the tiers it has not been able to see;
  • require the Client to disclose the labour standards provisions in its project documents, and where those provisions are absent or inadequate, advise in writing on the provisions in clause 9;
  • satisfy itself that a grievance mechanism will exist that is accessible to workers at the lowest tier, in a language they speak, without cost and without a requirement to complain through their own supervisor;
  • obtain, where a labour provider or recruitment agent is used, evidence of that provider’s licence or registration, its fee model, and confirmation in writing that no Recruitment Fee is charged to any Worker;
  • conduct, where the Company or its personnel attend a project site, a structured observation against the ILO Indicators, recording what was seen rather than what was reported; and
  • reassess the rating at each material change in project scope, contractor, financing or programme.
8.5
For Category A suppliers, the Company applies proportionate due diligence before engagement: self-declaration against the standards in clause 6 for low-risk professional services; and, for labour-intensive services such as facilities management, cleaning, catering, security and transport, evidence of right-to-work checks, of direct payment of wages to Workers’ own accounts, of the absence of Recruitment Fees, and of a grievance route.
8.6
The Company does not accept a supplier code of conduct, a policy document or a signed declaration as evidence that conditions on the ground are compliant. Documents evidence intent. Only observation, worker voice and independent verification evidence practice, and the Company records which of these it has and which it does not.
8.7
Where the Company is unable to obtain information sufficient to form a view on labour supply arrangements, and the Client or Counterparty declines to provide it, that refusal is itself treated as a finding. The Mandate must be escalated to the Responsible Officer and may not proceed without the written approval of a member of senior management.
8.8
Findings, escalations and decisions under this clause are recorded on the Mandate file and retained in accordance with the Data Retention and Records Management Policy (FGL-LEG-06).

9.Contractual expectations placed on counterparties

9.1
Every contract under which the Company engages a supplier, consultant, agent or other Category A or Category B Counterparty must contain obligations to the following effect, and the Company will not engage a Counterparty that refuses them:
  • (a)a warranty that the Counterparty and, so far as it is aware after due enquiry, each of its own suppliers and subcontractors, complies with the MSA and with all applicable labour law in each jurisdiction in which it operates;
  • (b)an undertaking that no Modern Slavery is or will be used in the performance of the contract, and that no Recruitment Fee is or will be charged to any Worker engaged in that performance;
  • (c)an undertaking not to retain any Worker’s identity or travel documents, not to require any deposit or bond, and to pay all wages directly and in full to the Worker’s own account at the intervals required by law;
  • (d)an obligation to notify the Company in writing, without delay, of any allegation, investigation, enforcement action or finding concerning Modern Slavery in its business or supply chain;
  • (e)an obligation to impose obligations no less onerous on each of its own subcontractors and labour providers, and to be responsible for their compliance;
  • (f)a right for the Company, or an independent party appointed by it, to request information, to conduct or commission an assessment, and to speak with Workers privately and without the presence of management;
  • (g)an obligation to co-operate in remediation in accordance with clause 12, including the reimbursement of Recruitment Fees to affected Workers where such fees have been charged;
  • (h)a right for the Company to suspend performance and to terminate the contract with immediate effect, without liability, on evidence of Modern Slavery that is not remedied within a reasonable period; and
  • (i)an acknowledgement that termination on that ground does not preclude reporting to a competent authority.
9.2
In respect of Category C Project Supply Chains, where the Company is not a contracting party, the Company advises its Clients in writing to incorporate equivalent provisions into project documentation, and in particular into the principal construction, operation and maintenance, labour supply and camp services contracts. The provisions the Company recommends include:
  • a flow-down obligation binding every tier of subcontractor, expressed so that it survives assignment and novation;
  • a prohibition on the engagement of any labour provider that is not licensed or registered where licensing or registration is required, and on the engagement of any unnamed intermediary;
  • mandatory disclosure by each contractor of the identity of every labour provider and of every subcontractor engaging manual labour, before mobilisation;
  • an express reimbursement obligation where a Recruitment Fee has been charged, payable to the Worker and not to the intermediary;
  • a requirement for written contracts of employment in a language each Worker reads, issued before recruitment costs are incurred, with no substitution of terms on arrival;
  • a requirement for an operational-level grievance mechanism meeting the effectiveness criteria of the United Nations Guiding Principles on Business and Human Rights, available to every tier;
  • audit and unannounced inspection rights exercisable at every tier, including access to payroll, recruitment records, age verification records and accommodation; and
  • remedy-first termination provisions, so that termination does not become the mechanism by which affected Workers lose both their livelihood and their remedy.
9.3
Where a Client declines to adopt the provisions recommended under clause 9.2, the Company records that fact and the reasons given, and the Responsible Officer reassesses the Mandate. Persistent refusal to adopt basic labour standards provisions in a high-risk project is a ground for declining or terminating the engagement under the Terms of Business (FGL-LEG-03).
9.4
The Company does not present contractual provisions as an outcome. A clause that is never tested is a clause that does not work, and the Company’s advice accordingly addresses verification and escalation as well as drafting.

10.The Company’s own workforce and recruitment

10.1
All individuals engaged by the Company are engaged directly, on written terms, in a language they read, setting out the work, the remuneration, the hours and the notice period. The Company does not engage workers through unlicensed intermediaries and does not use labour providers.
10.2
The Company pays at or above the applicable statutory minimum in each jurisdiction in which it engages personnel, pays directly into an account in the individual’s own name, pays at the intervals required by law, and issues an itemised statement of pay and deductions. The Company makes no deduction from pay by way of penalty, bond, deposit or recruitment cost.
10.3
No individual engaged by the Company is required to pay any Recruitment Fee. Where an individual is recruited internationally, the Company bears the cost of visas, permits, documentation, medical examinations required for the role, and travel to the place of work.
10.4
The Company does not retain any individual’s passport, national identity document, birth registration certificate or work permit. Documents are inspected for right-to-work and identity verification purposes, a record is made in accordance with the Privacy Policy (FGL-LEG-04), and originals are returned immediately.
10.5
Right-to-work and age verification checks are performed on every individual before engagement. The Company does not engage any person below the applicable minimum working age in any capacity.
10.6
Every individual engaged by the Company is free to terminate their engagement on the contractual notice period, is free to work elsewhere subject only to lawful confidentiality and conflict restrictions, and is under no restriction on movement of any kind.
10.7
Where the Company engages recruitment agencies, it engages only agencies that comply with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003 or, outside the United Kingdom, with equivalent licensing requirements, and it obtains written confirmation that no fee is charged to the candidate.

11.The limits of the Company’s influence

11.1
The Company states plainly what it can and cannot control, because a statement that overstates control is of no use to anyone who relies on it.
11.2
What the Company controls. Its own workforce and the terms on which it is engaged. Its own suppliers and the contracts under which they are engaged. Which Clients it accepts and which it refuses. Which Counterparties it introduces, recommends or endorses. What it advises, in writing, that a Client should require of its contractors. Whether it continues to act. Whether it reports.
11.3
What the Company influences but does not control. The labour standards provisions a Client adopts in its project documentation. The rigour with which those provisions are enforced by the Client and its principal contractor. The selection of subcontractors and labour providers below the first tier. The conditions in accommodation and transport provided at project sites. The conduct of a joint venture partner or state-owned counterparty.
11.4
What the Company does not control. The Company does not employ, pay, house, transport or direct any project workforce. It has no power of inspection, no power of entry and no power of sanction in respect of any Project Supply Chain other than such rights as its Clients confer or such access as is voluntarily granted. It cannot compel a contractor to reimburse a Recruitment Fee, cannot compel a public authority to act, and cannot guarantee the conduct of parties several tiers removed from any contract to which it is a party.
11.5
The Company does not treat the absence of control as the absence of responsibility. Where the Company lacks control it uses leverage: it advises in writing, it insists that questions are asked and recorded, it declines to introduce Counterparties it cannot get comfortable with, it escalates within the Client organisation, and where leverage fails and the harm is not remedied, it withdraws. Withdrawal is a last resort and is exercised in a manner intended not to worsen the position of affected Workers.
11.6
The Company makes no representation that any project on which it has advised is free of Modern Slavery. It represents only that it applies the process set out in this Statement, that it records what it finds, and that it acts on what it finds.
Advisory reach, honestly stated

An adviser cannot audit a workforce it does not employ on a site it does not run. What it can do is refuse the mandate, write down what it saw, tell the client in terms, require the contractual provisions that make enforcement possible, and leave when nothing changes. Those are real instruments and the Company uses them. Claiming more than that would be a fiction.

12.Response and remediation

12.1
Any person who identifies a Red Flag, or who receives a report of one, must report it to the Responsible Officer immediately and must not attempt to verify it first. The obligation arises on suspicion and does not require proof.
12.2
On receipt of a report, the Responsible Officer shall record it, assess the immediate risk to any affected Worker, and determine the response. The safety of the affected Worker is the first consideration and takes precedence over the Company’s commercial interests, over the Client relationship and over the preservation of evidence.
12.3
Where there is a credible indication that a person is in immediate danger, the matter must be reported without delay to the police in the jurisdiction concerned. In the United Kingdom, potential victims are referred through a First Responder organisation to the National Referral Mechanism; the Company is not a designated First Responder and will therefore make the referral through the police or another First Responder organisation, or direct the reporter to the Modern Slavery and Exploitation Helpline. Where the concern relates to labour exploitation in the United Kingdom, it may also be reported to the Gangmasters and Labour Abuse Authority. Where the concern relates to Bangladesh, the Company shall report to the relevant law enforcement authority and, where the matter concerns a registered workplace, to the Department of Inspection for Factories and Establishments, taking local legal advice where the reporting obligations of the two jurisdictions may conflict.
12.4
Where a report concerns the proceeds of forced labour or trafficking, the Responsible Officer shall consider with the Money Laundering Reporting Officer whether a disclosure is required to the National Crime Agency under the Proceeds of Crime Act 2002 or the Terrorism Act 2000, and no step may be taken in the meantime that would constitute tipping off.
12.5
The Company’s remediation expectations, which it will pursue with the Client and Counterparty concerned, are:
  • (a)the affected Worker is removed from the harm, and is not dismissed, deported, transferred or otherwise disadvantaged as a consequence of the finding;
  • (b)any retained identity or travel document is returned immediately;
  • (c)any Recruitment Fee charged is reimbursed in full to the Worker, together with any unlawful deduction and any unpaid wage;
  • (d)the Worker is offered continued lawful employment on compliant terms, or supported into alternative employment, according to the Worker’s own wishes;
  • (e)access to independent support, legal advice and, where the Worker chooses, the relevant national referral or victim support process is facilitated;
  • (f)the root cause is identified — whether pricing, programme, subcontracting depth or an intermediary — and corrected, so that the same conditions do not reproduce with a different workforce; and
  • (g)a written remediation plan is agreed with named owners and dates, and its completion is verified rather than assumed.
12.6
The Company will not treat the removal of an intermediary, the replacement of a subcontractor or the termination of a contract as remediation. Those steps address the Company’s exposure; they do not address the harm. Termination that leaves affected Workers unpaid and without recourse is a worse outcome than continued engagement coupled with enforced remedy, and the Company will advise accordingly.
12.7
Where remediation is refused or is not delivered within the period agreed, the Company shall cease to act on the Mandate, shall withdraw any introduction or endorsement it has given, and shall consider what further reporting is required. The Company will not resume work with a Counterparty in those circumstances without a documented assessment approved by the Board.

13.Measuring effectiveness

13.1
The Company measures the effectiveness of this Statement against indicators that record what was actually done, not what was intended. The indicators are reported to the Board at least annually and are maintained for year-on-year comparison.
13.2
The indicators are:
  • the proportion of Mandates for which a Modern Slavery screen under clause 8.2 was completed before acceptance, and the number completed late or not at all;
  • the number of Mandates rated medium or high, and the proportion of those for which a Project Supply Chain map was produced and the tiers not visible were expressly recorded;
  • the number of Mandates declined, suspended or terminated on Modern Slavery grounds, and the stage at which each decision was taken;
  • the proportion of Category A suppliers and Category B Counterparties under contracts containing the provisions required by clause 9.1;
  • the proportion of Mandates in which the Company advised in writing on the provisions in clause 9.2, and the proportion in which the Client adopted them;
  • the number of Red Flags reported, by source and by category of ILO Indicator, and the median time from report to first substantive response;
  • the number of remediation plans agreed, the number verified as complete, and the number of Workers reimbursed Recruitment Fees or unpaid wages as a result;
  • the number of reports referred to a law enforcement authority, a First Responder organisation or a regulator;
  • the proportion of personnel who completed Modern Slavery training within the required period, by role; and
  • the number of project sites at which Company personnel conducted a structured observation against the ILO Indicators, and the findings recorded.
13.3
The Company treats a nil return against the reporting indicators with suspicion rather than satisfaction. In sectors of the risk profile described in clause 7, an absence of reports is more likely to indicate that the reporting route is not reaching Workers than that no harm exists, and the Board shall test it on that basis.
13.4
Where an indicator shows deterioration, or where an indicator cannot be reported because the underlying record was not kept, the Responsible Officer must report the fact to the Board with a corrective plan, named owners and dates.
13.5
The Company does not publish indicator values in a form that could identify an individual Worker, a reporter, or a party against whom an allegation has been made but not established.

14.Training and awareness

14.1
Every director, officer, employee, consultant and secondee of the Company must complete training on Modern Slavery before commencing work on any Mandate and at least annually thereafter. Completion is a condition of continued access to Mandate work and training records are retained.
14.2
The training covers, as a minimum:
  • the offences under sections 1 and 2 of the MSA, the meaning of exploitation under section 3, and the transparency duty under section 54;
  • the ILO Indicators, and how each of them presents in a construction, quarry, port or camp environment rather than in the abstract;
  • the specific risk patterns described in clause 7, including intermediary recruitment, fee-charging, document retention, wage advances and deductions at source;
  • how to conduct a structured observation on a site visit, what to look at, what to record, and why what is said in the presence of a supervisor is not evidence;
  • the escalation route, the requirement to report on suspicion, and the prohibition on attempting to verify a report first;
  • the interaction between this Statement, the Client Due Diligence and Know Your Customer Standard, the Anti-Bribery and Anti-Corruption Policy and the Whistleblowing and Speak-Up Policy; and
  • the protections available to those who report, and the consequences of retaliation.
14.3
Personnel whose roles involve Mandate acceptance, counterparty assessment, contract drafting or site attendance receive enhanced training appropriate to those roles, including practical case study work drawn from the sectors in which the Company operates.
14.4
The Company makes a summary of this Statement, and of the reporting routes in clause 15, available to its Category A suppliers and to Counterparties on request, and encourages Clients to cascade equivalent awareness material through their Project Supply Chains in a language Workers read.
14.5
Training content is reviewed annually against the findings recorded under clauses 12 and 13, so that what is taught reflects what has actually been encountered.

15.Reporting routes and protection for those who report

15.1
Concerns about Modern Slavery may be raised by any person, whether or not connected to the Company, and whether or not the concern relates to a Mandate. Concerns should be submitted through the enquiry form at fratresgroup.com/contact, marked for the attention of the Responsible Officer. Reports are acknowledged within five business days and are assessed under clause 12.
15.2
A report may be made anonymously. The Company will act on an anonymous report, although it recognises that its ability to investigate and to provide feedback may be limited where it cannot make further enquiry of the reporter.
15.3
A report may be made in English or in Bengali. The Company will arrange translation where necessary and will not treat the language in which a concern is expressed, or its lack of legal precision, as a reason to discount it.
15.4
Personnel of the Company should raise concerns through the Whistleblowing and Speak-Up Policy (FGL-LEG-14), which provides the protected channel and describes the handling process. A qualifying disclosure made in accordance with Part IVA of the Employment Rights Act 1996, as inserted by the Public Interest Disclosure Act 1998, is protected, and any detriment or dismissal on that ground is unlawful.
15.5
The Company will not tolerate retaliation of any kind against a person who reports a concern in good faith, or who co-operates with an investigation. Retaliation is a disciplinary matter capable of amounting to gross misconduct, and where a Counterparty retaliates against a Worker who has reported, it is a ground for termination under clause 9.1.
15.6
The identity of a reporter is treated as confidential and is disclosed only where the reporter consents, where disclosure is required by law, or where it is necessary to protect a person from immediate harm. Where disclosure becomes necessary, the reporter will be told before it is made wherever it is safe and lawful to do so.
15.7
Nothing in this Statement, in any contract with the Company, or in any confidentiality or settlement provision, prevents or restricts any person from reporting Modern Slavery to a law enforcement authority, a regulator or a First Responder organisation, and any provision purporting to do so is of no effect.
15.8
Personal data provided in a report is processed in accordance with the UK GDPR and the Data Protection Act 2018, as described in the Privacy Policy (FGL-LEG-04). A complaint about the handling of personal data may be made to the Information Commissioner’s Office.

16.Governance, review and approval

16.1
The Board is accountable for this Statement and for the adequacy of the Company’s response to Modern Slavery risk. The Board considers the matter at least annually and additionally whenever a Red Flag is escalated to it.
16.2
The Responsible Officer is accountable for the day-to-day operation of this Statement, for maintaining the risk assessment required by clause 7.1, for the register required by clause 5.5, for the indicators required by clause 13, and for reporting to the Board on the operation of the Statement, the reports received and their outcomes, and any weakness identified.
16.3
Every individual to whom this Statement applies is responsible for applying it in their own work, for raising concerns without delay, and for recording what they observe. Compliance is a condition of engagement and a failure to escalate is a disciplinary matter.
16.4
The operation of this Statement is subject to internal review at least annually, covering a sample of Mandate files across each risk rating, the completeness of Modern Slavery screens, and the enforcement of the contractual provisions required by clause 9. Findings are reported to the Board with remediation actions, owners and deadlines, and the closure of each action is verified.
16.5
This Statement is reviewed at least annually and additionally whenever there is a material change in the law, in the Company’s risk assessment, or in the sectors or jurisdictions in which the Company operates. Each review considers whether the areas identified in clause 7 remain the areas of highest risk and whether the measures in clauses 8 to 12 remain adequate to them.
16.6
This Statement constitutes the Company’s slavery and human trafficking statement for the Statement Year for the purposes of section 54 of the MSA. It was approved by the Board of Fratres Limited and has been signed on the Board’s behalf by a director in accordance with section 54(6) of that Act. The signed copy is held by the Company and a copy may be requested through the enquiry form at fratresgroup.com/contact.
Enquiries

Questions about this Statement, requests for the signed copy, requests from Clients or Counterparties for the Company’s supply chain declarations, and reports of suspected Modern Slavery should be submitted through the enquiry form at fratresgroup.com/contact, marked for the attention of the Responsible Officer. Enquiries are acknowledged within five business days.

A concern that a person is in immediate danger should not be raised through this route. It should be reported to the police in the jurisdiction concerned without delay, and, in the United Kingdom, to the Modern Slavery and Exploitation Helpline or the Gangmasters and Labour Abuse Authority. A complaint about the Company’s conduct may be made under the Complaints Handling Procedure (FGL-LEG-17).

Related policies
Conflicts of Interest PolicyFGL-LEG-13Whistleblowing & Speak-Up PolicyFGL-LEG-14ESG & Responsible Business PolicyFGL-LEG-16Complaints Handling ProcedureFGL-LEG-17
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