Modern Slavery & Human Trafficking Statement 2019

Introduction

This statement is made by Mercury Engineering Unlimited Company (“Mercury”) on behalf of the entire Mercury group of companies, noting for the purposes of the Modern Slavery Act 2015 that part of its group includes Mercury Engineering and Building Services Limited, a UK registered company.

Mercury is committed to driving out acts of modern-day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners. Mercury acknowledges its responsibilities under the Modern Slavery Act 2015 and will ensure transparency within the organisation, with suppliers of goods and services and all others who make up the supply chain within Mercury.

Mercury operates within the construction industry in various countries throughout the European Union (EU) and has minority shareholdings in entities outside the EU. Depending on the geographical location and industry sector, Mercury provides general contracting, project management, mechanical engineering, electrical engineering, sprinkler and technical services.

It is acknowledged that the existence of slavery is a significant risk within the construction industry, and that the majority of people suffering from this predicament are in supply chains of legitimate industries.

Our Policies

Mercury is committed to a zero-tolerance approach to slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains.

To support this commitment, Mercury have developed policies, guidelines, training, monitoring and review mechanisms to inform our employees and suppliers of the values we expect to be upheld while employed or dealing with Mercury.

The Mercury Code of Business Conduct sets out the Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. Mercury have also implemented a Supplier Code of Conduct, which outlines Mercury’s principles on ethical procurement. This Supplier Code of Conduct sets out Mercury’s expectations of those who provide goods or services to the Group to ensure they meet applicable legal and ethical standards, including human rights and minimum labour standards.

These policies and guidelines are subject to continuing review.

Supply Chain

Mercury’s supply chain includes companies and/or goods from outside the EU. Imported goods from sources outside the EU are potentially more at risk of slavery and human trafficking issues. The level of management control required for these supply sources will be continually monitored in line with our procurement and compliance procedures. As part of our due diligence process during the supplier approval process, Mercury will review, where necessary, the controls that the suppliers have in place to mitigate against the risk of slavery and human trafficking in their organisation.

Mercury requires all its suppliers to adhere to Mercury’s standards and to be compliant with laws, regulations and social customs for the countries they operate in and with all human rights, labour and health and safety regulations.

Monitoring & Compliance

Mercury have established a Working Group to monitor and discuss potential high-risk areas, incidents and actions in relation to Modern Slavery. This Working Group meet on a periodic basis and consists of members from across Mercury, including Legal, HR, Health & Safety, Compliance, Procurement and Operations.

Mercury continually assesses and monitors potential risks in our supply chain and adheres to strict risk assessment procedures for all new suppliers. In addition, Mercury regularly conducts audits of our project sites, in line with our compliance programme, to ensure that our policies and procedures are fully adhered to.

Training & Awareness

Mercury makes its policies available to all employees, communicating on any relevant changes or updates. To support these policies, Mercury has, and will continue to, provide appropriate training to our employees to ensure business is conducted in an honest, ethical and professional manner. Mercury is committed to providing specific training with respect to the risks of slavery in construction industry to all staff.

Mercury also provides a Speak Up hotline, available 24 hours a day, 7 days a week in each country we operate, as a confidential reporting mechanism for employees and external stakeholders to report any improper or unethical behaviour.

Conclusion

Mercury is committed to taking all necessary steps needed to ensure that slavery in any form does not take place within the organisation.

Mercury’s approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2019 and beyond.

Mercury shall take responsibility for this statement and its objectives, and it will be reviewed and updated on an annual basis.

This statement has been approved by the Board of Directors of Mercury.

Signed on behalf of Mercury Engineering:

Eoin Vaughan

Eoin Vaughan
Chief Executive Officer, Mercury

Date: 26/06/19