This policy statement sets out the approach Walter Lilly & Co Limited has taken within the financial year, with the aim of ensuring that modern slavery or human trafficking is not taking place within our business or within our supply chain.

Walter Lilly structure, business and supply chain

Walter Lilly is a wholly owned subsidiary of Renew Holdings plc. We carry out construction work involving science, higher education, high quality private residential, restoration and structural refurbishment projects.
Modern Slavery can occur in many forms. For the purpose of this statement, modern slavery includes any act of
slavery, servitude, bonded, forced or compulsory labour, child labour or human trafficking. All of these acts are
conducted for either personal or commercial gain and result in the abuse and exploitation of an individual’s human rights. Integrity is one of the core values of Walter Lilly and we remain fully committed to the eradication of modern slavery in all its forms. As a Company we do not engage in, nor do we condone or tolerate, any act of modern slavery within any aspect of our operations.
We expect all employees, subcontractors and suppliers to comply with the following provisions:
 Adhere to local and national laws
 Freedom of workers to terminate employment
 Freedom of movement
 Freedom of association
 Prohibit any threat of violence, harassment and intimidation
 Prohibit the use of worker-paid recruitment fees
 Prohibit compulsory overtime
 Prohibit child labour
 Prohibit discrimination
 Prohibit confiscation of workers original identification documents
 Provide access to remedy, compensation and justice for victims of modern slavery
Walter Lilly are fundamentally a management company that employs a wide range of subcontractors to undertake
the construction work on our projects. Walter Lilly have a formal supply chain process where the selection,
appointment and future use of our subcontractors is managed. All employees, temporary workers, or subcontract
employees, who work at any site or business location operated by Walter Lilly will be required to conform fully to
the requirements of our Modern Slavery and Human Trafficking Policy and its supporting procedures. This includes
reporting any suspected act of modern slavery identified within the workplace to their line manager and director
for immediate investigation and action. We are committed to ensuring that there is no slavery or human trafficking
in our supply chain and it is our policy to implement effective and robust controls to ensure this is not taking place.
Our Supply Chain Contractor Qualification Questionnaire draws attention to the applicable legislation and
demands that our supply chain partners comply in full with it.
We are committed to the highest standards of openness, probity and accountability and our staff are requested to
report any suspicions of significant wrongdoing.
Walter Lilly only uses specified reputable employment agencies to source labour and always verifies the practices
of any new agency it is using before accepting workers from that agency. Walter Lilly have been using the same
three labour agencies for over ten years. We contact labour agencies on an annual basis and request that they verify
and demonstrate their compliance with the Modern Slavery Act 2015.
Walter Lilly clearly communicates to employees the actions and behaviours expected of them when representing
the organisation. The organisation strives to maintain the highest standard of employee conduct and ethical
behaviour when managing its supply chain.
Walter Lilly’s policies in relation to modern slavery and human trafficking
Walter Lilly has developed policies, to help ensure that modern slavery does not ever feature in our operations.
These include:
 Modern Slavery and Human Trafficking Statement (Ref POL-COR-SLA)
 Contractor Qualification Questionnaire (CQQ) (Ref FRM-BSC-CQQ)
 Subcontractor Pre Order Agreement (Ref MET-SER-POR)
Due diligence
The Modern Slavery compliance requirements are outlined within our Supply Chain Contractor Qualification
Questionnaire, pre-order meeting minutes and subcontractor orders. We will never knowingly accept products and
services from subcontractors and suppliers who exploit people or natural resources to create their products and
services.
Risk management and continuous monitoring
Our primary risk area is within our supply chain. Therefore, achieving transparency of labour employment
arrangements and sourcing of materials are areas of focus. Walter Lilly communicates and demonstrates our
commitment to our supply chain using the pre order procurement process and the Contractor Qualification
Questionnaire. We engage with our supply chain as appropriate, to understand what measures they are taking to
ensure that modern slavery is not occurring within their business or their own supply chain.
Walter Lilly takes a zero-tolerance approach to slavery and we are committed to ensuring that operations and
supply chains are free from slavery or human trafficking.
Every employee will be familiar with our ethical standards and policies to ensure no slavery occurs within the
business, and are encouraged to report any potential breaches. Our statement is visible for all staff to view on the
company’s website and intranet as well as being provided during induction.
Training on modern slavery and trafficking
Walter Lilly draws attention to the Modern Slavery Act 2015 and requires our staff, subcontractors and suppliers to
comply with its requirements, and our annual Slavery and Human Trafficking Statement is posted to the staff
intranet.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015.

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