Introduction
As a leading global consultancy, we have a responsibility to use the influence we have, through delivering some of the world’s largest infrastructure projects, to make a positive change for those who need it most.
This is captured in our Purpose:
To improve society by considering social outcomes in everything we do; relentlessly focusing on excellence and digital innovation, transforming our clients' businesses, our communities and employee opportunities.
A key part of this is our approach to addressing modern slavery and more widely respecting human rights. We reject modern slavery in all its forms, including servitude, forced or compulsory labour, child labour and human trafficking. We recognise that there are risks of modern slavery in every country and any industry and aim to work only with those suppliers who operate in a way that is consistent with Our Code – Delivering with PRIDE and can meet the standards that we set on rejecting modern slavery.
This statement confirms our compliance with Section 54 of the UK Modern Slavery Act 2015. In setting our policies and processes we aim to follow best practice as well as the UK Government guidance ‘Transparency in supply chains’. In addition to publishing this statement on the Mott MacDonald Group website, we will also publish it on any associated websites to promote our commitment to this agenda.
This statement covers the whole of the Mott MacDonald Group and its worldwide operations, with the exception of our JN Bentley business based in the UK. It should be noted that our business in Australia (Mott MacDonald Australia Pty Limited) has also published a Modern Slavery statement in accordance with the Modern Slavery Act 2018.
Mott MacDonald's organisation's structure:
Mott MacDonald is a US$2bn engineering, management and development consultancy involved in:
- Solving some of the world’s most urgent social, environmental and economic challenges
- Helping governments and businesses plan, deliver and sustain their strategic goals
- Responding to humanitarian and natural emergencies
- Improving people’s lives
Our expertise by sector includes advisory, built environment, energy, international development, transport and water. Our skills encompass planning, studies and design, project finance, technical advisory services, project and programme management, management consultancy and beyond.
Our Code – Delivering with PRIDE, consolidates our commitment to doing what’s right and building an ethical culture throughout Mott MacDonald. It sets out our standards and expectations on the issues that matter to us; it is a guide for making good choices and living our PRIDE values: – Progress, Respect, Integrity, Drive, and Excellence. These guide our behaviour, shape our culture and inform our relationships with our clients, stakeholders and each other.
By following Our Code, we build stronger, more trusting relationships with our clients, communities and colleagues and increase our ability to comply with country specific, federal and local laws, and regulations. We follow local legislation and regulation wherever we work. However, where Our Code provides the higher standard, we expect that to apply.
Being employee-owned frees us to choose the work we take on and focus on the issues that are important to our clients – and us. We’re not in business to make the most profit for external shareholders: we want to do a great job for our clients, our communities and our people. We insist on the highest standards of integrity in all we do. We were the first consultancy firm to be certified to the UK’s anti-bribery management standard, BS 10500, and when BS 10500 was superseded, we built on this by achieving certification to the international standard ISO 37001.
We operate globally with one corporate set of policies, directives and requirements through a common online business management system. Through this approach, all our colleagues in the Mott MacDonald Group, whether employed in the UK company or around the world are required to comply with the UK Modern Slavery Act 2015 as well as any national legislative requirements, for example the Modern Slavery Act 2018 in Australia.
Our supply chain
We recognise our responsibilities to ensure that our supply chain complies with International Labour Organisation conventions and have proper respect for the people supplying services to them. We are committed to achieving the ethical standards we set for ourselves with our supply chain and continue to work towards full transparency. Modern slavery aspects are included in our standard supplier and joint venture contracts in the UK.
We seek to work only with those who share our values and operate in a manner consistent with Our Code – in their dealings with us and within their own supply chains. We conduct due diligence checks on our clients, suppliers and partners. We communicate our expectations, monitor performance and address any issues. This includes withdrawing from contracts if our standards are not being met.
The modern slavery risks the business faces can broadly be divided into the following categories of supply chains in our business operations:
- Facilities management (FM) staff (office cleaning, janitorial, security, etc.) in our 140 offices across the world.
- Organisations providing resources or services to support the delivery of our business, such as suppliers of personal protective equipment, office supplies, catering organisations, accommodation and travel companies.
- IT and other office equipment, such as furniture
The above groups can be further subdivided into labour that is:
- Directly employed (MML group companies being the contracting party)
- Sub-contracted, where we employ a service agency who is the contracting party
- Associated labour, whereby our joint venture (JV) partners are the contracting party, or they sub-contract to agencies to provide labour
In all cases we seek to ensure that our purchasing practices do not create pressure on our suppliers that could lead to modern slavery for example, avoiding aggressive pricing that does not consider production costs, late payments or imposing unfair penalties.
In our UK and Europe region all our approved suppliers are held on a central database which staff can consult prior to engagement. Those we have identified as higher risk such as our central UK facilities management contract, our personal protective equipment supplier and our furniture suppliers are subject to additional questions at tender stage and during regular contract reviews. We also carry out some spot checks for payments of a living wage and audits for working conditions at manufacturing facilities.
Our policy
Our approach to respecting people and our suppliers is also embedded in our policies on slavery and human trafficking, equality, diversity and inclusion, integrity, human resources, risk treatment, procurement, safeguarding, and social responsibility.
Due diligence process
As a predominantly professional services body, the vast majority of Mott MacDonald’s direct employees are not considered vulnerable, or at risk from modern slavery. In relation to slavery and human trafficking in our business, we:
- Employ individuals through an interview process, whether they are full-time employees or contract staff. This process seeks to confirm individuals share our corporate values, have a right to be employed for a specific job, are not breaching immigration regulations; have the necessary competence and aptitude for the position and are applying to work for us through their own free will.
- Seek to provide a living wage for all directly employed staff.
- In our supply chain, we evaluate all potential and existing suppliers using a standard questionnaire to identify competence, compliance with our values and standards and to ensure they are addressing slavery and human trafficking risks. This assessment is repeated periodically. The process is supported through our procurement processes. We are currently reviewing our global approach to procurement to identify best practice and strengthen this area in the future.
Due diligence on clients and suppliers is undertaken through combining our previous experience of working with the organisation, our local knowledge of them and the information surfaced through the Exiger Insight3PM service. This consists of an initial web- based search on a company and its affiliates, with a more comprehensive review available if needed.
We verify that we hold up-to-date and accurate information about our suppliers, supported by our supplier questionnaire prior to engagement. We check they comply with the requirements in our policies on modern slavery, ethics and anti-bribery, and they divulge essential financial and structural information to us. Following appointment, suppliers are assessed annually via a formal record of performance.
Risk management framework
As stated, as a professional services organisation, our risks associated with slavery and human trafficking of direct employees are generally low. Our professional staff have tertiary education, are often members of professional organisations and command significant levels of compensation in line with market norms.
It is acknowledged that our risks related to modern slavery vary between the countries and sectors we work in.
Together with an external partner, we have carried out a preliminary set of geographically based country risk assessments focussing on modern slavery. Countries to be assessed were prioritised by the current level of risk: using the Global Slavery Index data and taking into account our activities in- country combined with the sector and region. This framework enables the business to assess the level of modern slavery risk, for a particular project in a specific country, based on likelihood and severity. We will continue to develop this area over the coming year, adding more countries to be assessed and providing briefings and guidance to our Territory Managers, Bid and Project Managers and senior leadership teams.
To further support the business we have produced best practice guidance for our project managers and teams to help them identify key areas of risk and to implement appropriate control measures to mitigate the risks. This has been integrated into our health and safety risk assessment process and training has been provided to our global safety managers and project safety advisors to support project staff. The areas of risk identified can be broadly grouped as:
- Outsourced low wage jobs, such as office cleaners, drivers and support staff
- Our commodity purchasing supply chain eg personal protective equipment, IT equipment, office furniture, tea and coffee, where unskilled labour is prevalent
- The construction related supply chains of our partners and clients around the world
- Staff untrained in recognising the signs of modern slavery
- Working with joint ventures (JV) and sub-consultants
- Failure to report and investigate suspected modern slavery issues
We interface closely with the construction industry around the world and undertake some traditional construction activities in the UK through the JN Bentley business. These activities are covered in a bespoke modern slavery statement.
Effectiveness of our approach
As we deem the risk of slavery and human trafficking in our own business to be low, we monitor the performance of our suppliers in supporting us to meet our policy commitment and the services they provide to us. We also monitor our own compliance with our employment and procurement processes. In addition, we are audited around the world by third party organisations both for compliance with our internal business processes and with quality standards. We are confident this approach is appropriate to managing our risks for our tier one suppliers.
Speaking up
Our Speak Up helpline is a comprehensive and confidential internet and telephone-based reporting tool provided and managed by an independent third party (Navex Global – EthicsPoint). We have strict processes in place which are published on our intranet as part of our business management system. The service is promoted through campaigns within the company, including via posters in our offices. It is accessible to anyone, including all tiers of our supply chain including facilities management staff in all of our offices. Reports are treated confidentially and can be raised anonymously where local legislation allows. During 2021 we did not receive any reports (internal or via Speak Up) related to modern slavery or human trafficking.
Training and awareness
We train all our staff on ethics and compliance with our values, directives and processes. We also provide training on people management and communications skills and these are directly aligned with our PRIDE values. This creates a strong culture of tolerance of others, transparency in decision-making and mutual respect, that supports our training module on Modern Slavery which is available to all staff.
Our Code- Delivering with PRIDE, is our new code of conduct/ethics, which contains our standards and the expectations for all our staff on Modern Slavery and human rights. All staff within the business complete training on Our Code and read and certify that they have complied with it. Our Code is made available to our suppliers and via our external website and highlights our desire to work only with those who can meet our standards and expectations, including aspects relating to Modern Slavery and human rights. Our Code helps all those who work for us, or with us, to improve their understanding of Modern Slavery and how to raise any concerns, should they come across any.
Launching Our Code in 2021 provided all staff with a basic understanding of human rights and modern slavery issues. We are now in the process of undertaking a training needs analysis to identify additional roles which would benefit from enhanced training, ie those who are more likely to come into contact with victims of modern slavery. We expect this to be a minority of staff involved in managing supplier contracts.
In 2022 we will run an internal engagement campaign around Modern Slavery to coincide with the publication of this Statement.
Our progress in 2021:
We built on our existing project management requirement to ensure that modern slavery issues are considered at the start of relevant projects by adding additional detail to assist bid teams in assessing the level of modern slavery risk. This includes consideration of sector, country and suppliers A trigger point to make people consider the risk has been built into our existing processes.
We engaged with our 50 plus Territory Managers on modern slavery risks and issues. We also engaged on an individual basis to engage on specific country risks based on our activities and supply chains to feed into the risk assessment framework.
We’ve recently been accredited as a Living Wage Employer by the Living Wage Foundation, meaning that we can now demonstrate that every colleague working for Mott Macdonald in the UK earns the real Living Wage. Receiving this accreditation solidifies our commitment to fairly compensate not only directly employed staff but also to our third party contracted staff.
We have increased our conversations with our clients and external organisations on modern slavery.
Progress against our 2021 targets
2021 target
We will specifically include modern slavery as part of our new Code of Conduct for all staff and those working on our behalf. This will cover key principles and actions for everyone, will be launched in late 2021 and will be supported by additional training material which we will be able to update based on current priorities. All our suppliers will be asked to confirm that they are working to and implementing equivalent standards as part of their contract with us.
Progress made
Modern slavery and human rights were key topics in Our Code under the topic of ‘Respecting human rights.’ Additional resources were provided to assist with learning and understanding, including a set of dilemmas for discussion, frequently asked questions and dos and don’ts. The dilemmas are used to help teams have better conversations and to build staff understanding of Our Code and have been frequently used to enhance regular team meetings.
Our Code is shared with our suppliers who confirm that they have an equivalent Code of Conduct.
Status: complete
2021 target
We are undertaking a review of our due diligence process to explore how we can better identify our highest risk suppliers and constructively engage with our supply chain on modern slavery and human rights issues. This goal is likely to extend beyond the current calendar year because of the size of the organisation, and trialling any new systems developed will take place in one geographical area before any further roll out.
Progress made
The review is complete and a project is currently being initiated to implement the findings from the review.
Status: Complete
2021 target
We are reviewing our procurement process for our large UK contracts to explore how we can better assess our suppliers for modern slavery issues at the tender stage and during contract reviews.
Progress made
Additional assessment questions were added into our selection process for large UK contracts. As part of a recent tender evaluation downstream PPE manufacturers were examined.
Status: Complete
2021 target
We will share the UK procurement approach with the wider business, through establishing an internal network of regional procurement contacts and using this network to share best practice.
Progress made
Our global procurement network was surveyed to understand the current position across the world and what control measures are currently in place. We held a preliminary meeting with the team to share our results and introduce the topic.
Status: In progress
2021 target
We are working to better understand and develop risk ratings for countries we work in, using the Global Slavery Index. Outcomes from this work will be fed into our risk assessment approach in our business management system.
Progress made
We partnered with Control Risks Group to assess our activities in a number of key countries with higher risks for modern slavery, and now have a suite of risk assessments, focussing on high-risk sectors and locations in the country and likely implications for us. We will continue to build on this over the coming year to add to the list of countries we assess.
Status: stage 1 complete
2021 target
We are working to increase our external engagement with NGO’s, competitors, clients and suppliers on Modern Slavery issues.
Progress made
We are a member of the United Nations Global Compact. We have held discussions with several of our clients on modern slavery issues.
Status: In progress
Targets for 2022
- Improving the guidance available for our project management and procurement staff on modern slavery risks and the control measures that need to be put in place to minimise the risk of modern slavery instances in our supply chains.
- Improving the modern slavery training we have in place for our frontline staff, specifically working on training modules for our site-based staff and those who visit projects who are most likely to encounter modern slavery in the course of their work.
- Continue to identify and brief other key staff such as safety managers, office managers and procurement staff on our role in combatting modern slavery.
- Provide additional training to our safety staff to assist them in assessing modern slavery risk and discussing control measures with the staff in their business units.
- Helping to identify what good looks like for procurement specialists to more effectively assess suppliers.
- Implement the findings from the due diligence review carried out in 2021, which will include ESG due diligence.
- Developing and promoting more modern slavery learning resources as part of an ongoing internal interactive learning programme.
- Join an anti-slavery NGO to greater increase our capacity to make changes inside our organisation and in wider society.
- Identify and prioritise gaps in our modern slavery risk management framework against industry good practice.
- To continue to increase our score on the UK Government’s Modern Slavery Assessment Tool.
The above statement has been approved by the Executive Board of Mott MacDonald and is signed on their behalf by Mr James Harris, Group Managing Director.
James Harris
June 2022