Anti- Slavery and Human Trafficking
Policy Statement
Last Updated July 2026
The Company recognises that slavery, human trafficking and illegal workers remain a concern throughout today’s
society and as Managing Director of NU City Civils Limited (NCC) I accept overall responsibility for compliance with
the requirements of the Modern Slavery Act 2015 and sections 15 to 25 of the Immigration, Asylum & Nationality Act
2006.
This policy statement applies to all employees, potential employees and within the company and to third party suppliers
with access to NU City Civils or client property, systems or data, and any other parties working on behalf of NCC
Limited.
This Policy Statement sets down our commitment to preventing slavery, human trafficking and illegal workers in our
business activities and the steps we have put in place with the aim of ensuring that there is no slavery, human trafficking
or illegal workers in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are
expected to report their concerns to the Managing Director and management team to act upon them.
NU City Civils is committed to supporting the elimination of acts of Modern Slavery and accordingly we acknowledge
and comply with the. Within our remit, we encourage others to support the following and as such ask our suppliers to
confirm their commitment as we do to the:
UN Declaration of Human Rights
UN Guiding Principles on Business and Human Rights
Core Conventions of the International Labour Organisation
Prohibition of forced or compulsory labour for our employees, contractors, and sub- contractors
Prohibition of employees, contractors, and sub-contractors being forced into involuntary labour and coercion at work and
financial penalty as a disciplinary sanction is prohibited
Our employment models deployed across our Company will be in line with territory specific law and practices
Declaration to confirm support of the Modern Slavery Act 2015 will be contained in our updated supplier contracts and
existing suppliers will be required to complete this declaration on renewal
Robust communications programmes to ensure all employees and particularly those with procurement responsibility are
aware of their responsibilities
NU City Civils considers that the adherence with this act is in line with the corporate values and ethical code which it
promotes.
NU City Civils will achieve these aims by our initiative to identify and mitigate risk in the following ways but not
limited to:
Employee training in order establish understanding of requirements,
More stringent vetting and investigation of our supply chain (contractors, sub-contractors, policies, contracts
etc.).
Continually audit & review 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 the protection of whistleblowers.
The company 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 and
contractors comply with our values.
NU City Civils carry out appropriate VISA, Passport and DOB checks to ensure all employees are entitled to work in the
UK in accordance with Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006.
Should a non-UK resident apply to work with us, a copy of their work visa and passport would be required. All necessary
checks would then be made to ensure the person had the right to work in the UK and they have no immigration
restrictions that prevent them from doing the work in question. Documentation used to verify the right to work shall be
compliant with the Home Office Guidance for employers preventing illegal workers shall be retained for a minimum of 2
years after the individual has left our employment.
Should a potential employees’ right to work in the UK be on a temporary basis, additional checks will be carried out to
ensure that their documents have been renewed prior to them commencing employment to prevent a situation where their
working rights would expire during their period of employment.
We will use the following methods to measure how effective we have been to ensure that slavery, human
trafficking and the use of illegal workers is not taking place in any part of our business or supply chains:
Completion of internal Audits.
Use of labour monitoring and payroll systems.
Level of communication and personal contact with next link in the supply chain and their understanding of, and
compliance with, our expectations.
Annual Senior Management review.
NU City Civils will undertake due diligence when considering taking on new suppliers and regularly reviews its existing
suppliers. The Company’s due diligence process includes the building of long-standing relationships with suppliers and
making clear our expectations of business partners.
This policy shall be communicated to all employees on initial induction and following policy changes, be communicated to
suppliers as necessary and other interested parties and be reviewed regularly annually as a minimum.
_________________
Donald McCulloch
Managing Director