Anti Slavery

Advantage NRG Modern Slavery Statement

Advantage NRG adopts a zero-tolerance approach to modern slavery, human trafficking and any form of bribery and corruption within our operations or supply chain.

Statement for financial year ending March 2023

Introduction

The Modern Slavery (“act”) was introduced to help eradicate slavery, forced labour and human trafficking in the operations and supply chains of companies. This statement is made pursuant to Section 54, Part 6 of the Act and includes information about Advantage NRG, its own operations and supply chains, and how we are approaching zero tolerance of slavery and human trafficking within our business.

Our commitment

Advantage NRG is committed to preventing and mitigating exploitation, bribery and corruption. We will not accept modern slavery, forced labour and human trafficking anywhere within our operations or supply chain. We are committed to undertaking a risk analysis of our supply chain to further develop a plan to improve transparency and accountability in our supply chain.

Our commitment is set out in further detail in our Anti-Slavery and Human Trafficking Statement: NRG_ASHTP_V4.0_07.07.2022

Advantage NRG structure

Advantage NRG is a Limited Company led by our Managing Director Nick Adams. The company structure overseen by the Managing Director consists of General, Commercial, Operational, SHEQ and Office Management. The most current organisational structure diagram can be found in the business manual for SHEQ Management.

Advantage NRG has produced an anti Slavery and human trafficking statement, though the identification of risk areas and activities outlined in this statement, they apply equally to all departments within Advantage NRG.

What Advantage NRG does

Advantage NRG is a specialist, labour only, sub-contractor. We use our own skilled labour force to build and maintain electrical transmission systems.

Founded in 2011, we serve major utility contractors throughout the UK. Our staff work in self sufficient teams of 4-7 men to undertake all aspects of work for the refurbishment, upgrading, re-wiring, dismantling and construction of high voltage, overhead line steel tower and wood pole supported transmission systems.

Advantage NRG operations

We directly employ 111 staff as a combination of office-based staff, field supervisors and Line workers, with the majority of our workforce being line workers.

The men we supply and manage are trained, and network authorised Supervisors, Chargehands and Line Workers complete with tools and fall arrest equipment. Our staff are trained to the highest standards and work proactively with our clients to ensure work is delivered on time, safely to the technical specifications and quality standards expected. This includes administrative, technical, safety, training, competency and operational delivery.

We are confident that our own operations are free of modern slavery, forced labour and human trafficking. We supply labour from overseas, including the Philippines and South Africa. Our recruitment processes comply with employment laws of the countries we recruit from. Our operations and the supply of our managed labour in the UK is in accordance with UK employment law and UKVI home office regulations.

Health, safety and well-being support is in place for all staff including access to a dedicated HR support function who can if required source mental health specialist counselling support.

Policies

We have a range of employment policies in place which ensure that our employees are fairly treated, supported, remunerated and understand the behaviour expected by the organisation. These policies include

Anti bribery and corruption
Anti Bullying and harassment
Anti-slavery and human trafficking statement
Corporate social responsibility
Employee confidentiality
Equal opportunities
Equality and diversity
Maladministration and malpractice
Whistleblowing

Supply chains and risk areas

We have a team of recruitment and procurement specialists managing recruitment and procurement processes. We recruit from overseas including the Philippines and South Africa. The suppliers we use to deliver our equipment and consumables, and our own operations, are primarily UK based.

We contract with a range of suppliers and agencies, from large international recruitment companies to local cleaning and catering companies. We have an approved preferred supplier list detailed in our integrated SHEQ Management system Client/Supplier Contact Book - NRG_OM/SCB_V1.0_05.06.2023. Our risk analysis of our supply chain allows us a better understanding of supply contracts where there is a greater risk of exploitation.

We also create, negotiate and have access to a series of frameworks – and contractual agreements put in place with our customers and suppliers. These contracts and frameworks ensure those who rely on us are reassured that they have identified modern slavery risks. We are exploring how we can improve our oversight of our suppliers.

Our modern slavery policy describes our obligations in reporting breaches of the modern slavery regulations and Advantage NRG’s whistleblowing policy explains how members of staff can also report breaches.

Due diligence

As part of our approach to maintaining a supply chain that is free of modern slavery, forced labour and human trafficking, going forward we will require commercial organisations meeting the criteria within the Modern Slavery Act 2015 to provide a copy or link to their anti-slavery statement. Our own modern slavery policy is shared with our suppliers during procurement processes. We will design and roll out a self-assessment questionnaire to all suppliers identified within our high-risk areas and will monitor how this can be rolled out further or where additional due diligence checks need to be implemented.

Responsible recruitment

We continually review our recruitment processes to ensure we are doing all we can to mitigate modern slavery. We have focused on incorporating this into our interactions with candidates at the hiring and onboarding stage. We use reputable agencies when selecting, screening and hiring candidates, comply with laws of the countries we recruit from and comply with UKVI regulations and home office requirements when bringing new employees into the UK.

Training and awareness raising

Awareness raising amongst our employees is key to ensuring that risk areas are recognised, and employees know what to do if they become aware of any concern associated with exploitation. All recruitment and procurement staff going forward into 2024 will be required to complete a mandatory modern slavery awareness training course on a training platform and repeat every two years. The modern slavery policy and this statement will also be actively shared with all staff to help colleagues understand their responsibility as individuals to report behaviour which they believe suggests a breach of the Act. Our whistleblowing policy includes appropriate guidance for staff in reporting any suspicion of inappropriate or illegal behaviours.

Collaboration and partnership working

Building effective partnerships and strategic alliances with our customers and clients to guide us in our future plans will be an ongoing action we will begin to explore to progress our community support and modern slavery objectives as an organisation.

Actions in the last reporting year

  • SHEQ Manager is a member of the supply chain sustainability school
  • We have reviewed the Global Slavery Index 2023
  • We have reviewed the following policies:
    • Anti bribery and corruption
    • Anti Bullying and harassment
    • Anti-slavery and human trafficking statement
    • Corporate social responsibility
    • Employee confidentiality
    • Equal opportunities
    • Equality and diversity
    • Maladministration and malpractice
    • Whistleblowing

We have not received any reports of potential or actual breaches of the Act and no procurements or contracts have been terminated as a result of concerns regarding compliance with the Act.

Future plans

In the coming financial year (from 1 April 2023 to 31 March 2024), we will:

  • Review how to engage with our suppliers about modern slavery – design and review self-assessment questionnaires from high-risk suppliers and bid submissions, and working with customers and clients and mutually support where appropriate
  • Continue the risk analysis of our supply chain with ongoing reviews of our existing supply chain to identity areas for improvement via the modern slavery self-assessment questionnaire
  • Continue to explore enhanced training for the departments overseeing high risk area suppliers to raise further awareness, and roll out more widely as we believe is necessary
  • Review supplier’s modern slavery statements regularly to assess existing suppliers and aim to request these annually from suppliers
  • Continue to raise awareness of modern slavery within advantage NRG