Modern Slavery Policy

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out some background to our organisation and our supply chains, and the steps which we have taken to combat slavery and human trafficking for the financial year ending 2023.

Our Business and Supply Chains

RFM Group’s end-to-end property services include facilities management, repair and construction within the defined target sectors that include retail, residential, commercial and education.  RFM Group has enabled the efficient and cost-effective delivery of thousands of new, refurbished and managed properties throughout the UK.  RFM Group has approx. 50 employees across the UK on two sites in Leeds and Edinburgh and has a registered address in London.

Within our supply chain, there are relationships with external businesses for the sourcing of [sub-contractors, labour and supply partners] in the UK.  These, as well as the suppliers of services, make up the supply chains within the Company.

As part of our due diligence processes to prevent slavery and human trafficking, our:

· Supplier set-up process will require suppliers to outline the controls they have in place. Imported products from sources outside the UK and EU are potentially more at risk for slavery/human trafficking issues.

· Operation Managers and Contracts Managers will continually monitor the level of management control required.

· Procurement Team will report on this annually to our Strategic Executive team. Continual audit and review of our practices for checking all employees are paid at least the minimum wage and have the right to work

· We encourage the reporting of concerns and protection of whistle blowers

· RFM Group will not knowingly support or deal with any business involved in slavery or human trafficking

· We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values

· To ensure understanding of these risks within our supply chain and our business we provide training to relevant members of staff. All directors have been briefed on the subject.

Supplier Adherence to Our Values

RFM Group expects all suppliers and any subcontractors engaged by the organisation to respect and conform to our fundamental values as conditions for mutual business. Our standard terms and conditions require all of our suppliers to comply with the law.

We have a zero-tolerance approach to slavery and trafficking. We have appointed a Head of Safety, Health Environment & Quality who will have overall responsibility for ensuring that all those in our supply chain and contractors comply with our values.

We’ll make reasonable endeavours to ensure employees and workers aren’t subject to any form of forced, compulsory or bonded labour in our supply chains.

Employees should have freedom to terminate their employment at any time without penalty, giving reasonable notice. We’ll not knowingly support or deal with any business involved in slavery or human trafficking.

Our Strategic Executive Team and Senior Management will take responsibility for implementing this statement and its objectives. They’ll ensure adequate resources (training and administration etc.) and investment to ensure slavery and human trafficking isn’t taking place within our organisation or within our supply chains.

We’ve zero tolerance of any threat of physical or sexual violence, harassment, or intimidation against employees and their family, or close associates.

RFM Group Services Ltd policies and guidance will be clearly defined and communicated to all of our employees. Employees won’t suffer any detriment to their salary or benefits unless it falls under our terms and conditions of service.

Our Policies on Slavery and Human Trafficking

RFM Group is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This statement reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

RFM Group implements a number of policies and procedures which are designed to minimise the risk of modern slavery and human trafficking, both within our organisation and our supply chains. We continue to review our policies to ensure that they remain effective and appropriate for the business.

Anti-bribery and corruption policy – this policy helps create a culture where bribery is never acceptable and providing guidance to all staff to report and deal with the risks of fraud and corruption.

Dignity at work policy – this policy sets out RFM Group’s commitment to providing a working environment free from harassment and bullying and helps to ensure that all of our staff are treated, and treat others, with dignity and respect.

Health and safety policy – one of the key aims of this policy is to ensure the wellbeing of all our employees, contractors and anyone else who may be affected by our activities.

Recruitment policy – we carry out appropriate checks to ensure that all of our staff have the requisite right to work documentation, that they are paid fairly and that they receive a competitive remuneration package for the work they undertake.

Whistleblowing policy – this provides guidance on how to report suspected dangers or wrongdoing in the workplace. All of our staff are expected to be alert to the risks, however small, in both our business and the wider supply chain.

All our employees are treated fairly and equally. They are paid at least the national minimum wage, or the London living wage and are provided all organisational benefits. Salary payments are made directly to employees and will not be delayed, deferred, or withheld. Only deductions, advances or loans authorised in law are permitted with the full consent of the employee. Clear and transparent information will be provided to employees about hours worked, rates of pay and the calculation of legal deductions.

Our employees won’t be forced to work in excess of the number of hours permitted in law. Normal working hours and overtime won’t exceed 48 hours per week average over a 17-week period unless the employee agrees.

Stringent vetting of our supply chain

Continual audit and review of our practices for checking all employees are paid at least the minimum wage and have the right to work

We encourage the reporting of concerns and protection of whistle blowers

RFM Group will not knowingly support or deal with any business involved in slavery or human trafficking

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with our values

To ensure understanding of these risks within our supply chain and our business we provide training to relevant members of staff. All directors have been briefed on the subject.

Due Diligence Processes

RFM Group will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chains:

Completion of audits by Directors, Managers and Safety, Health, Environment and Quality Managers

Labour monitoring and payroll systems

Level of communication and personal contact with the next link in the supply chain, including their understanding of and compliance with our expectations