Modern Slavery Act

June 2024

Murphy has a zero-tolerance approach to Modern Slavery which is the use of forced, compulsory or trafficked labour or the holding of anyone in slavery or servitude whether they are adults or children. We are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all our supply chain partners. We expect them to adopt the same zero tolerance approach to Modern Slavery. We expect our supply chain partners to hold their own suppliers to the same high standards.

Murphy is an international, multi-disciplined engineering and construction company. J Murphy & Sons Limited is the main trading company of the Murphy group of companies (‘the Group’). The Group has over 4000 employees worldwide and operates in the United Kingdom, the Republic of Ireland and as part of a joint venture in Canada and North America. The Group had a global annual revenue of more than £1 billion in 2023.

Our supply chains include in the region of 2,500 suppliers, with around 250 of these suppliers accounting for 80% of our expenditure on a regular basis. Our direct suppliers are predominantly UK or EU based and support our business in the provision of labour, plant, materials, equipment and professional services.

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships. We are committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. This is guided by one of the core values of business: Respect, Integrity and Accountability.

We take responsibility for conducting and growing our business in a safe, sustainable, and responsible manner. We understand the impact our activities can have on the environment and society around us. We endeavour to ensure we eliminate or mitigate the risk of negative impacts and leave a positive legacy in the communities where we work. Our Murphy at 75 strategy sets out specific targets around Climate Action and Social Value making sustainable decision making an integral part of the way we do business. We also have policy statements in relation to Environment, Social & Governance (ESG) and Sustainable Procurement which are made available internally and to our supply chain.

We have signed the Construction Protocol with the Gangmasters and Labour Abuse Authority (GLAA), and with other members of our industry, to support the objective of eradicating slavery and labour exploitation in the sector.

The Group has also signed the Supply Chain Sustainability School’s People Matter Charter that commits us to ensuring that basic human rights are protected and exploitation in the workplace is eliminated.

Our Anti-Slavery Policy sets out our approach to Modern Slavery and applies to everyone working directly or indirectly for or with us. We recognise that appropriate training on modern slavery and the use of forced, compulsory or trafficked labour will increase awareness among our people as well as mitigating the risk within the business and the supply chain.

Modern Slavery compliance is an integral part of our supplier approval and pre-qualification processes. As part of our supply chain accreditation process, we require our supply chain to comply with the Modern Slavery Act 2015. We include our Anti-Slavery Policy in our contracting processes to ensure our supply chain are aligned against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

We use standard industry accreditation schemes to certify our supply chain’s compliance with Modern Slavery requirements. This is carried out on an annual basis.

We recognise that the construction sector has particular risks relating to modern slavery and is one of the sectors where the GLAA has the most referrals and cases to investigate.

We consider the following key risks relating to modern slavery for our business are:

• The multiple tiers in our supply chain where goods which may be manufactured in jurisdictions which have greater risk of forced labour or child labour.
• Supply of labour through agencies or other third parties which is subject to coercion and under the control of organised criminals.
• Engaging direct labour which is subject to coercion and under the control of organised criminals.

We manage these risks:

• By committing our direct supply chain to complying with our Anti-Slavery Policy.
• By selecting responsible providers through a proper due diligence process and continued engagement with them on their labour resources.
• By right to work and other identity checks on commencement of employment.
• By training and educating our people.
• By auditing our supply chain partners’ compliance with our policies.

We adopted the following KPIs in 2023 to measure our effectiveness in assessing and managing the risk of modern slavery:

• Include modern slavery compliance in our Sustainable Procurement Policy.
• Require supply chain partners to provide a copy of their modern slavery policy, or other policy detailing the steps being taken to ensure that Modern Slavery does not occur in their business.
• Complete 15 audits on Modern Slavery compliance in the supply chain.
• Co-ordinate toolbox talks on all projects with Anti- Slavery Week in October 2023.

All the above KPIs were achieved in 2023.

We have adopted the following KPIs in 2024 to measure our effectiveness in assessing and managing the risk of modern slavery.  

• Undertake an external audit on our processes for eliminating and mitigating the risk of Modern Slavery in our business and supply chain.
• Complete 15 audits on Modern Slavery compliance in the supply chain.
• Co-ordinate toolbox talks on all projects with Anti- Slavery Week in October 2024.

We recognise that appropriate training on Modern Slavery will increase awareness among our people, as well as mitigating the risk within the business and the supply chain.

Our Code of Conduct forms part of our induction process for all new starters and is a compulsory training requirement for existing employees within the business. It explains what Modern Slavery is and informs our people that it is their responsibility to help prevent, detect, and report incidences of Modern Slavery. It advises our people to raise concerns about incidences of Modern Slavery through management or our independent confidential helpline managed by Safecall.

We are partners of the Supply Chain Sustainability School, through which we provide specific training to our procurement team on the relevant legislation. Our procurement team also take the CIPS ethics course annually.

We have included in our toolbox briefings to our projects, a specific briefing on Modern Slavery advising our people on the warning signs to look out for where there may be incidences of modern slavery and advising them how to report any concerns.

The business’s approach to the prevention of Modern Slavery has stakeholder buy in from the highest levels of management within our organisation. The policy has been considered and formally ratified by the Board. The Company Secretary and General Counsel is the appointed Compliance Officer.

The Compliance Officer is responsible for dealing with any concerns about compliance with the Act as well as the protections in place for anyone who brings matters of concern to our attention.

We are satisfied that we have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistleblowers.
• We have no reason for concern in relation to any current member of the supply chain and their compliance with the Modern Slavery Act.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to all companies in our Group including our parent company, Drilton Limited and all of our subsidiary companies.

It constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st December 2023 and outlines the steps we have taken as an organisation to assess our operations and supply chain and mitigate any risk of slavery and human trafficking.

John Murphy, Chief Executive Officer
J. Murphy & Sons Limited

June 2024