MODERN SLAVERY POLICY
This policy is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that JDT Utilities has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Our company has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business
JDT Utilities are a major utility contractor, primarily providing gas mains renewal and replacement services. We have a wide & varied supply chain and maintain good communications and relations with all.
Our policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
1.Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery andexplains how employees can identify any instances of this and where they can go for help.
2.Recruitment policy. We operate a robust recruitment policy, including conducting eligibility towork in the UK checks for all employees to safeguard against human trafficking or individuals beingforced to work against their will.
3.Whistleblowing policy. We operate a whistleblowing policy so that all employees know that theycan raise concerns about how colleagues are being treated, or practices within our business or supplychain, without fear of reprisal.
4.Bribery Policy. The purpose of this policy is to establish controls to ensure compliance with allapplicable anti-bribery and corruption regulations, and to ensure that the Company’s business isconducted in a socially responsible manner.
Our suppliers
JDT operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
1.They have taken steps to eradicate modern slavery within their business
2.They hold their own suppliers to account over modern slavery
3.They pay their employees at least the national minimum wage / national living wage (as appropriate)
4.(For international suppliers) They pay their employees any prevailing minimum wageapplicable within their country of operations
5.We may terminate the contract at any time should any instances of modern slavery come tolight.
Our performance indicators
We will recognise the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
•No reports are received from employees, the public, or law enforcement agencies to indicatethat modern slavery practices have been identified.
Warning Signs
Be suspicious of counterfeit and fraudulent items if you encounter any of the following warning signs:
1)
Identification Markings
Alterations, wrong size, location, marking method incorrect, smudged or blurred, lot or batch numbers missing, incorrect supplier’s logo
2)
Product Condition
Resurfaced / refinished, evidence of re-work, wrong colour, shape or size, evidence or previous use (used item)
3)
Paperwork / Certificate of Conformity
Accompanying paperwork has poor spelling or grammar, errors or evidence of tampering, missing information or does not relate to the delivered product
4)
Lot Information
Unusual serialisation or reference numbers, lot information missing
5)
Chain of Ownership
Unverifiable traceability to source
6)
Unusual Location
Items delivered from a location differing from previous or from prohibited countries
7)
Low Price
A price significantly lower than historical pricing data or market norm
8)
Availability
Obsolete or scarce items suddenly becoming available
9)
OEM Certification
Unavailable OEM certification or uncertified OEM
10)
Unfamiliar Supplier
Supplier or agent / stockist not known or previously used