In addition to being responsible in our operations, Harworth is also committed to being a responsible employer as part of its role as an employer of choice. This includes appropriately developing and supporting its staff (as described in ‘Our People’), alongside working safely and fully complying with all relevant aspects of UK law as this section explains.
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Health and safety
Health and safety has an extremely high profile in our business. Day-to-day review and management rests with our Estates, Environment and Safety (“EES”) team, led by our Associate Director of EES. The EES team reports to our Company Secretary, who has a wider responsibility for governance, risk and compliance. Our Chief Executive has ultimate responsibility for all health and safety matters.
Harworth’s Safety, Health and Environment Management System (“SHEMS”) is based on the “Plan, Do, Check and Act” model advocated by the HSE. The EES team maintains a site risk register which rates each of our sites as “low risk”, “medium risk” or “high risk”, from a health and safety perspective. A medium or high risk rating recognises that action needs to be taken at the site, whether within a prescribed timetable (medium risk sites) or immediately (high risk sites). All our low and medium risk sites are inspected at least annually and our high risk-rated sites are inspected more regularly. At the date of this report, there were no “high risk” sites in the site risk register. The overall risk profile of our sites is reported to Board monthly. Material movements in this profile are fed into the quarterly reviews of the Group Risk Register (see the Managing Risk section of this report on pages 34 to 44).
Our EES team ensures that health and safety is embedded into all our activities. In 2018 mandatory health and safety training was delivered to all employees in the form of online tuition and testing. There was also targeted training for certain employees, such as training on The Construction (Design and Management) Regulations 2015 (“CDM”) and asbestos handling which was delivered to our Major Developments and Operations teams. The team is scheduled to host a mandatory safety training day for all employees in June. This follows the success of a similar training day hosted in 2017. Further proactive safety initiatives are undertaken in the form of health and safety inspections and audits. The geographical spread of our sites is large and the type of sites is varied. Any issues reported, whether they are incidents or accidents, are logged and appropriate follow up action is undertaken and monitored by the EES team. This process is key to identifying areas for improvement across the portfolio.
We continue to engage JPW Consultancy Limited (“JPW”), an external health and safety consultant, to advise on health and safety issues across the business. JPW focuses on health and safety at our Major Development sites, including management of consortium meetings between Harworth and stakeholders at these sites, such as contractors and local authorities.
There were only three minor accidents recorded at our sites during the year. For completeness, this statistic includes accidents involving contractors we have supervised. Where we have appointed a principal contractor under CDM they and their sub-contractors take responsibility for health and safety whilst works are ongoing, but we continue to monitor health and safety via JPW and/or our project managers.
There were no RIDDOR accidents or incidents or lost-time accidents reported by Harworth or any contractors working on Harworth sites during the year.
We are keen to ensure that the “health” in health and safety has equal prominence. Three of our employees now hold a mental health first aid qualification and those with traditional first aid qualifications have refreshed their training. Alongside this we have continued to promote ancillary measures designed to improve health and wellbeing amongst our staff, such as the construction of shower facilities at our Head Office for those who wish to exercise during the working day.
In terms of monitoring health and safety across our portfolio:
- meetings are held between our Company Secretary and the EES team monthly, following which our Associate Director of EES reports to both our Management Board and the Board. Those reports include incident briefings, where applicable, as well as an overview of activity on our sites and the overall risk profile of the portfolio;
- a report on health and safety forms part of the Chief Executive’s monthly update to the Board;
- there are quarterly safety meetings chaired by our Chief Executive, attended by employees from a cross-section of the business; and
- our Associate Director of EES reports to the Board in January each year on key issues encountered and actions undertaken during the previous year and priorities for the coming year.
Tackling modern slavery, bribery and corruption, and facilitation of tax evasion
We are committed to having in place practices to safeguard respect for human rights, to combat slavery and human trafficking in our business and those of third party contractors, to ensure that no corruption or bribery takes place in our business or supply chain, and to ensure that our employees do not deliberately or inadvertently act in such a way as to facilitate tax evasion.
The Company has published Modern Slavery Statements in 2017 and 2018. A copy of the 2018 statement appears on the opening page of our website at www.harworthgroup.com. The Company will publish another statement before the end of June 2019, which will reflect the progress that has been made since publication of the 2018 statement. In that regard, we can report that: (A) online training on tackling modern slavery and human trafficking has been delivered to all of our employees; (B) all new suppliers who have been approved during the year have committed to complying with our Supplier Code of Conduct on anti-slavery and human trafficking; and (C) our suite of precedent consultancy agreements are now in place, which impose obligations on our consultants in relation to anti-slavery and human trafficking.
The following policies are also in place:
- Anti-Corruption and Bribery;
- Gifts, Donations, Sponsorship and Hospitality; and
- Anti-facilitation of tax evasion.
They are available on the Group’s shared drive and reminders are sent to employees periodically. Our policies on anti-corruption and bribery and anti-facilitation of tax evasion are also published on our website. During 2018 online training was delivered to all employees on the prevention of bribery and corruption. We also engaged Grant Thornton to run a workshop on the management and mitigation of risks associated with facilitating tax evasion.
The Gifts, Donations, Sponsorship and Hospitality policy imposes a regime for the approval of business development activity at all levels of the business and a register of all activity. At the start of 2019 it was updated to reflect the changes to our senior management structure effected in 2018. The register of business development activity is monitored regularly by the Company Secretary and annually by the Audit Committee.
General Data Protection Regulations
We do not hold extensive amounts of personal data but recognise the importance of protecting the data that we do control. Workstreams were undertaken at the start of 2018 to ensure that the Group was, and remains, compliant with the GDPR, ahead of its coming into force on 25 May 2018. Those workstreams included:
- an internal audit and “mapping” exercise of personal data, resulting in the establishment of a “Personal Data Master Record” which will be a living document which remains subject to review;
- the implementation of a new data protection policy, with accompanying operational guidelines, such as for handling data subject rights;
- new fair-collection (privacy) notices; and
- the incorporation of data processing terms and conditions into our agreements with third parties with whom we share personal data.
Work is ongoing to embed a culture of GDPR compliance into the business. This will form part of a wider suite of initiatives designed to ensure appropriate information security across the business. These implement recommendations from a strategic review of information security undertaken by NCC Group (“NCC”). Further information on that review and NCC’s recommendations can be found in the Audit Committee report on page 98. One of the recommendations was the appointment of an information security manager. That appointment has been made and he is leading the implementation of all other initiatives, which will include steps to embed the above-mentioned measures, monitor their effectiveness, and improve GDPR awareness amongst employees.
From 2019, the Audit Committee will undertake an annual review of the Group’s ongoing compliance with GDPR.