This statement relates to InfraStrata plc, covering all business regions, operating companies and business units throughout the world, including wholly owned and partly owned subsidiaries. The statement relates to the financial year ending 31 July 2020.

At InfraStrata we are committed to conducting our dealings, whether with customers, suppliers, employees or the communities in which we are based, with the utmost integrity and as such we are steadfast in our support for the elimination of modern slavery in all its forms. All our businesses, wherever they are located and wherever they have dealings in the world, are required to respect people and to value their diversity.

Our aim is to create an inclusive organisation where everyone’s skills and contributions are welcomed and valued as well as being embedded in our attitude to health and safety.

This statement explains the steps InfraStrata is undertaking to prevent, detect and respond to modern slavery within our business and supply chains.

John Wood
Chief Executive Officer
for and on behalf of InfraStrata plc and group companies

October 2019


Our business is principally involved in the delivery of critical, complex engineering which support energy infrastructure, ship-building and associated services.

We operate in the following key markets: defence, energy infrastructure, heavy fabrication and shipyard related activities, providing services to predominantly governmental or blue-chip customers, all of whom are located in the UK, Europe or North America.

  • Strategic Suppliers: Supplier collaboration is strategically focused supporting mutual growth
  • Preferred Suppliers: These are business selected suppliers with whom we have scale trading relationships. Collaboration delivers added value and enhanced performance
  • Key Suppliers: These are important suppliers who are key to effective business operations
  • Mandatory Suppliers: These are entities with whom we must transact (for example local or national tax authorities and customer specified suppliers)

In addition to sector specific activities we have a Group-led category management approach for common expenditure across the InfraStrata group. These leads provide subject matter expertise into Business Units and Bids and support supplier development activities in the following areas:

  • Plant & General Engineering
  • Facilities Management
  • Corporate Services
  • IT
  • Construction

Slavery and human trafficking policies

We welcome the opportunity to contribute positively to global efforts to ensure that human rights are understood and observed.

As an international business we recognise our responsibility for upholding and protecting the human rights of our employees and other individuals with whom we deal in our operations across the world.

We believe that a culture of respect for and promotion of human rights is embedded throughout our business and can be demonstrated by our commitment to ethical conduct in everything we do. We expect the same commitment from our suppliers and for them to flow down that commitment through the Supply Chain.

The InfraStrata Code of Conduct describes the Company’s expectations of all those suppliers doing business with InfraStrata. In addition to communicating InfraStrata’s values, it mandates full compliance with all laws and regulations. It also addresses the proper handling of intellectual property and other sensitive data, health, safety and environmental concerns as well as Human Rights.

This Group-wide Code of Conduct is designed to provide clarity about our expectations of methods used to deliver environmental and social responsibility. The code reflects the same standards that we hold ourselves and enables a consistent approach to our customers in delivering to the highest ethical standards.

Code of Conduct

Our suppliers should either be willing to subscribe to our Code or have equivalent standards and procedures in their own businesses.

Key Areas
  • Inclusion and diversity
  • Dignity and respect
  • Human Rights
  • Anti-bribery and corruption
  • Gifts and hospitality
  • Conflicts of interest
  • Anti-trust and competition
  • Health and safety
  • Environment
  • Community engagement
  • Intellectual property
  • Confidential information
  • Cyber security
Due Diligence
  • Whistle-blowing

Due diligence procedures

We continue to deploy our modern slavery risk assessment via our due diligence tool-sets for new and existing suppliers.

This due diligence tool-set assists with supply chain awareness and facilitates measurement of supplier mitigation activities relating to modern slavery. This tool-set continues to be reviewed on an annual basis.

Businesses should use appropriate processes to qualify, on-board and periodically re-validate suppliers, to ensure compliance with commercial, regulatory and legal requirements.

The supplier qualification process is fully explained in our Procurement & Supply Chain functional principles and sector specific policies. The level of detail gathered from the supplier is appropriate to the type of supply.

Identifying, assessing and managing risk

We continue to believe that our exposure to the risks of modern slavery is low within our own business and supply chain.

This assessment is under continuous review so that we can determine if circumstances change that require us to take additional actions. We work in collaboration with other industry leaders to create a process that optimises risk management whilst encouraging the use of SMEs. InfraStrata requires potential suppliers to demonstrate their capability to meet our contractual requirements. We also look for a clear demonstration of commitment to corporate social responsibility. We expect high standards of conduct from our suppliers in what they will do for us or our customers and will not accept any behaviour contrary to our codes.

Effective action taken to address modern slavery

No instances of modern slavery have been identified during the year in any of our sectors in 2018/19.

Training and awareness

We are raising awareness of Modern Slavery across the business to ensure employees have a clear understanding of the issues and how to proceed where a risk is identified.

We have a clearly defined process about confidential whistle-blowing that can be used for reporting breaches of the codes of conduct.

We continue to raise awareness of Modern Slavery in which we explain the current legislation, InfraStrata policy and internal escalation points.